U.S. GOVERNMENT PRINTING OFFICE

67–438 WASHINGTON :

" ! HOUSE OF REPRESENTATIVES 

112TH CONGRESS

1st Session 

REVIEW NO.

2010

11–6574

OFFICE OF CONGRESSIONAL ETHICS 

UNITED STATES HOUSE OF 

REPRESENTATIVES

—————

Report and Findings 

Transmitted to the 

Committee on Ethics 

on May 18, 2011 

and released publicly pursuant to H. Res. 895 of the 

110th Congress as amended 

May 2011 

2:20 Nov 01, 2012 Jkt 067438 PO 00000 Frm 00003 Fmt 4012 Sfmt 4012 C:\DOCUMENTS AND SETTINGS\BJNEAL\DESKTOP\DAVE 
(II)

OFFICE OF 

CONGRESSIONAL ETHICS 

BOARD

UNITED STATES HOUSE OF REPRESENTATIVES

ONE HUNDRED TWELFTH CONGRESS

PORTER GOSS, Chair

DAVID SKAGGS, Co-Chair

YVONNE BURKE 

KAREN ENGLISH 

ALLISON HAYWARD 

JAY EAGEN 

WILLIAM FRENZEL 

ABNER MIKVA 

Omar S. Ashmawy, Chief Counsel & Staff 

Director

Kedric L. Payne, Deputy Chief Counsel 
(1)

REPORT

REVIEW NO. 11–6574 

The Board of the Office of Congressional Ethics, by a vote of no 

less than four members, on April 29, 2011, adopted the following 

report and ordered it to be transmitted to the Committee on Ethics 

of the United States House of Representatives. 

SUBJECT: Representative Jean Schmidt 

NATURE OF THE ALLEGED VIOLATION: Representative Jean 

Schmidt may have received free legal services that are considered 

gifts under House rules. Since 2008, three lawyers for the Turkish 

American Legal Defense Fund (‘‘TALDF’’) have represented her in 

various legal matters related to a complaint that she filed with the 

Ohio Election Commission against Mr. David Krikorian, a challenger to her congressional seat. 

The Turkish Coalition of America (‘‘TCA’’) has paid the TALDF lawyers a total of approximately $500,000 for the legal services provided to Representative Schmidt during the past three years. TCA 

currently pays the lawyers to represent her in an ongoing defamation suit that she filed against Mr. Krikorian in Ohio state court. 

Representative Schmidt has not paid for any of the legal services. 

If Representative Schmidt accepted free legal services without establishing a legal expense fund, she may have violated House rules. 

She also may have violated House rules and federal law by not including the free legal services as gifts on her financial disclosure 

statements.

RECOMMENDATION: The Board of the Office of Congressional 

Ethics recommends that the Committee on Ethics further review 

the above allegations because there is substantial reason to believe 

that Representative Schmidt: (1) accepted legal services from 

TALDF without establishing a legal expense fund; and (2) failed to 

report the legal services on her financial disclosure statements for 

calendar years 2008 and 2009. 

VOTES IN THE AFFIRMATIVE: 6 

VOTES IN THE NEGATIVE: 0 

ABSTENTIONS: 0 

MEMBER OF THE BOARD OR STAFF DESIGNATED TO 

PRESENT THIS REPORT TO THE COMMITTEE ON ETHICS: 

Omar S. Ashmawy, Staff Director & Chief Counsel. 

(3)

TABLE OF CONTENTS 

I. INTRODUCTION .......................................................................................... 5 

A. Summary of Allegations ................................................................... 5 

B. Jurisdictional Statement .................................................................. 6 

C. Procedural History ............................................................................ 6 

D. Summary of Investigative Activity .................................................. 6 

II. TALDF LEGAL SERVICES PROVIDED TO REPRESENTATIVE 

SCHMIDT ................................................................................................... 7 

A. Law, Regulations, Rules, and Standards of Conduct ..................... 7 

B. TALDF Has Provided Legal Services to Representative Schmidt 

for Nearly Three Years .................................................................. 8 

C. Representative Schmidt Received an Advisory Opinion from the 

Committee in 2010 ......................................................................... 12 

D. Relevant and Material Information May Not Have Been Provided to the Committee Concerning the Nature of the Legal 

Services ............................................................................................ 13 

E. TCA Has Paid Approximately $500,000 to Three Law Firms 

for the Legal Services Provided to Representative Schmidt ....... 15 

F. Representative Schmidt Accepted Additional Legal Services 

After Receiving the Advisory Opinion .......................................... 15 

G. Representative Schmidt Did Not Disclose the Legal Services 

She Received on Her Financial Disclosure Statements for Calendar Years 2008 and 2009 ........................................................... 17 

III. CONCLUSION ............................................................................................... 17 

(5)

1The Committee on Standards of Official Conduct was renamed the Committee on Ethics in 

the 112th Congress. 

FINDINGS OF FACT AND CITATIONS TO LAW 

Review No. 11–6574 

On April 29, 2011, the Board of the Office of Congressional Ethics (the ‘‘Board’’) adopted the following findings of fact and accompanying citations to law, regulations, rules, and standards of conduct (in italics). The Board notes that these findings do not constitute a determination that a violation actually occurred. 

I. INTRODUCTION 

1. In 2008, the Turkish Legal Defense Fund (‘‘TALDF’’) began 

providing legal services to Representative Schmidt in connection 

with a complaint that she filed against Mr. David Krikorian before 

the Ohio Election Commission. 

2. In 2009, TALDF continued to provide the legal services at no 

charge to Representative Schmidt. In September 2009, Representative Schmidt requested a written advisory opinion from the Committee on Standards of Official Conduct (the ‘‘Committee’’) 1 concerning payment of the legal services. She did not request a written 

opinion prior to accepting the legal services. 

3. In February 2010, the Committee on Ethics wrote an opinion 

advising Representative Schmidt that she could pay for the legal 

services by either establishing an approved legal expense fund to 

pay for the legal services or using campaign funds. The opinion was 

based on the facts that Representative Schmidt presented to the 

Committee. The letter from the Committee expressed its understanding that Representative Schmidt was awaiting a bill from the 

TALDF lawyers and that the legal services had not been paid. 

4. Apparently, relevant information concerning the nature of the 

payment of the legal services was not provided to the Committee. 

For example, it was not disclosed that the Turkish Coalition of 

America (‘‘TCA’’) had already paid the TALDF lawyers approximately $300,000 for Representative Schmidt’s legal services at the 

time of the advisory opinion. TCA paid the expenses for Representative Schmidt since 2008 and continues to pay for legal services in 

2011.

A. SUMMARY OF ALLEGATIONS 

5. The Board finds that there is substantial reason to believe 

that Representative Schmidt violated House Rule 25, clause 3 by 

accepting legal services from TALDF, which the TCA paid for prior 

to her receiving approval from the Committee of a legal expense 

fund.
6

2 H. Res. 895, 110th Cong. § 1(e), as amended (the ‘‘Resolution’’). 

3 A preliminary review is ‘‘requested’’ in writing by members of the Board of the OCE. The 

request for a preliminary review is ‘‘received’’ by the OCE on a date certain. According to the 

Resolution, the timeframe for conducting a preliminary review is thirty days from the date of 

receipt of the Board’s request. 4 According to the Resolution, the Board must vote on whether to conduct a second-phase review in a matter before the expiration of the thirty-day preliminary review. If the Board votes 

for a second-phase, the second-phase begins when the preliminary review ends. The secondphase review does not begin on the date of the Board vote. 

6. The Board finds that there is substantial reason to believe 

that Representative Schmidt violated House Rule 26, clause 2 and 

the Ethics in Government Act by failing to report the legal services 

that she received from TALDF as gifts on her financial disclosure 

statements for calendar years 2008 and 2009. 

B. JURISDICTIONAL STATEMENT 

7. The allegations that are the subject of this review concern 

Representative Jean Schmidt, a Member of the United States 

House of Representatives for the 2nd District of Ohio. The Resolution the United States House of Representatives adopted creating 

the Office of Congressional Ethics (‘‘OCE’’) directs that, ‘‘[n]o review 

shall be undertaken . . . by the board of any alleged violation that 

occurred before the date of adoption of this resolution.’’ 2 The House 

adopted this Resolution on March 11, 2008. Because the conduct 

under review occurred after March 11, 2008, the OCE has jurisdiction in this matter. 

C. PROCEDURAL HISTORY 

8. The OCE received a written request for a preliminary review 

in this matter signed by at least two members of the Board on January 24, 2011. The preliminary review commenced on January 25, 

2011.3 The preliminary review was scheduled to end on February 

23, 2011. 

9. At least three members of the Board voted to initiate a second-phase review in this matter on February 22, 2011. The secondphase review commenced on February 24, 2011.4 The second-phase 

review was scheduled to end on April 9, 2011. 

10. The Board voted to extend second-phase review for an additional period of fourteen days on April 5, 2011. The second-phase 

review ended on April 23, 2011. 

11. Representative Schmidt submitted a written statement, 

under Rule 9(B) of the OCE’s Rules for the Conduct of Investigations, on April 25, 2011. 

12. The Board voted to refer the matter to the Committee and 

adopted these findings on April 29, 2011. 

13. This report and findings were transmitted to the Committee 

on May 18, 2011. 

D. SUMMARY OF INVESTIGATIVE ACTIVITY 

14. The OCE requested and received documentary and, in some 

cases testimonial information, from the following sources: 

(1) Representative Schmidt; 

(2) Representative Schmidt’s Chief of Staff; 

(3) TCA President; 

(4) TALDF Lawyer 1; 

(5) TALDF Lawyer 2; and 
7

5Memorandum from Committee on Standards of Official Conduct to All Members, Officers, 

and Employees Regarding Legal Expense Fund Regulations, dated June 10, 1996 (‘‘Legal Expense Fund Regulations’’) (Exhibit 1 at 11–6574—0003). 6 Id. The Legal Expense Fund Regulations allow the acceptance of pro bono legal services 

under the following limited circumstances: ‘‘to file an amicus brief in his or her capacity as a 

Member of Congress; to bring a civil action challenging the validity of any federal law or regulation; or to bring a civil action challenging the lawfulness of an action of a federal agency, or 

an action of a federal official taken in an official capacity, provided that the action concerns a 

matter of public interest, rather than a matter that is personal in nature.’’ Id. 7 5 U.S.C. app. 4, § 102(a)(2)(A). 

(6) TALDF Lawyer 3. 

II. TALDF LEGAL SERVICES PROVIDED TO 

REPRESENTATIVE SCHMIDT 

A. LAW, REGULATIONS, RULES, AND STANDARDS OF CONDUCT 

Gifts

15. Pursuant to House Rule 25, clause 5(a)(1)(A)(i), ‘‘[a] Member 

. . . of the House may not knowingly accept a gift except as provided in this clause.’’ 

16. Under House Rule 25, clause 5(a)(3)(E), the gift rule exempts 

‘‘a contribution or other payment to a legal expense fund established 

for the benefit of a Member, officer, or employee that is otherwise 

lawfully made in accordance with the restrictions and disclosure requirements of the [Committee].’’ 

17. The Committee’ Legal Expense Fund Regulations provide that 

‘‘[n]o contribution shall be solicited for or accepted by a Legal Expense fund prior to the Committee’s written approval of the completed trust document (including the name of the trustee).’’ 5

18. ‘‘Pro bono legal assistance for other purposes shall be deemed 

a contribution subject to the restrictions of these regulations.’’ 6

Financial Disclosure 

19. Under House Rule 26, ‘‘the provisions of title I of the Ethics 

in Government Act of 1978 shall be considered Rules of the House 

as they pertain to Members, Delegates, the Resident Commissioner, 

officers, and employees of the House.’’ 

20. The Ethics in Government Act provides that ‘‘[e]ach report 

filed pursuant to section 101 (d) and (e) shall include a full and 

complete statement with respect to the following . . . The identity 

of the source, a brief description, and the value of all gifts aggregating more than the minimal value as established by section 

7342(a)(5) of title 5, United States Code, or $250, whichever is 

greater, received from any source other than a relative of the reporting individual during the preceding calendar year . . . .’’ 7

B. TALDF HAS PROVIDED LEGAL SERVICES TO REPRESENTATIVE 

SCHMIDT FOR NEARLY THREE YEARS 
8

8Memorandum of Interview of TALDF Lawyer 1, March 28, 2011 (‘‘TALDF Lawyer 1 MOI’’) 

(Exhibit 2 at 11–6574—0006); Memorandum of Interview of TCA President, April 8, 2011 (‘‘TCA 

President MOI’’) (Exhibit 3 at 11–6574—0012). 9TALDF Lawyer 1 MOI (Exhibit 2 at 11–6574—0006); TCA President MOI (Exhibit 3 at 11– 

6574—0012). 10TALDF Lawyer 1 MOI (Exhibit 2 at 11–6574—0007); TCA President MOI (Exhibit 3 at 11– 

6574—0012). 11TALDF Lawyer 1 MOI (Exhibit 2 at 11–6574—0007); TCA President MOI (Exhibit 3 at 11– 

6574—0012). 12TALDF Lawyer 1 MOI (Exhibit 2 at 11–6574—0007); TCA President MOI (Exhibit 3 at 11– 

6574—0012). 13TALDF Lawyer 1 MOI (Exhibit 2 at 11–6574—0007). 14 Id. 15 Id. at 11–6574—0006. 16Memorandum of Interview of TALDF Lawyer 2, March 28, 2011 (‘‘TALDF Lawyer 2 MOI’’) 

(Exhibit 4 at 11–6574—0016). 17TALDF Lawyer 3 Response to OCE Request for Information, dated February 11, 2011 

(‘‘TALDF Lawyer 3 RFI Response’’) (Exhibit 5 at 11–6574—0020). 18TALDF Lawyer 1 MOI (Exhibit 2 at 11–6574—0006). 19 Id. 20 Id. 21George J. Hochbrueckner & Associates, Inc. Lobbying Report for TCA dated January 15, 

2009 (Exhibit 6 at 11–6574—0027). 22TCA President MOI (Exhibit 3 at 11–6574—0011–0012). 23 Id. at 11–6574—0011. 24 Id at 11–6574—0012. 

TALDF in General 

21. TCA created TALDF in late 2007 or early 2008.8 The purpose of TALDF is to protect the legal rights of Turkish Americans.9

TALDF works primarily on defamation and free speech matters.10

22. TALDF provides legal services to its clients on a pro bono 

basis.11 The entity is funded by the TCA.12

23. If there is a legal matter in which the client is awarded monetary damages, the money is divided between the client and the 

TCA.13 The TALDF lawyers do not receive any portion of a damage 

award.14

24. TALDF has two lawyers in Washington, DC: TALDF Lawyer 

1 and TALDF Lawyer 2. TALDF Lawyer 1 is employed at the law 

firm of Bruce Fein & Associates, Inc.15 TALDF Lawyer 2 is employed at the law firm of Saltzman & Evinch, P.C.16

25. TALDF Lawyer 3 is local counsel in Ohio for Representative 

Schmidt and is employed at the law firm of Chester, Willcox & 

Saxbe.17

26. The TALDF lawyers are similar to independent contractors 

for TALDF.18 Each law firm bills TCA an hourly rate for legal services performed on behalf of TALDF.19 TCA pays for the services.20

27. TCA retained a registered lobbyist in 2008 until the lobbyist, 

George Hochbrueckner, terminated the registration effective December 31, 2008.21

28. The TCA President told the OCE that he is the head of TCA’s 

congressional outreach group.22 He spends approximately fifty percent of his time working on congressional outreach, which involves 

meeting with Members of Congress to discuss the Armenian genocide resolution and Greek and Turkish issues.23

29. The TCA President told the OCE that he has not registered 

as a lobbyist because he only educates legislators.24
9

25TALDF Lawyer 1 Response to OCE Request for Information, dated February 14, 2011 

(‘‘TALDF Lawyer 1 RFI Response’’) (Exhibit 7 at 11–6574—0030); TALDF Lawyer 1 Legal Service Invoices (‘‘TALDF Lawyer 1 Invoices’’) (Exhibit 8 at 11–6574—0033–0057); TALDF Lawyer 

2 Response to OCE Request for Information, dated February 17, 2011 (‘‘TALDF Lawyer 2 RFI 

Response’’) (Exhibit 9 at 11–6574—0059–0063); TALDF Lawyer 2 Legal Service Invoices 

(‘‘TALDF Lawyer 2 Invoices’’) (Exhibit 10 at 11–6574—0065–0072); TALDF Lawyer 3 RFI Response (Exhibit 5 at 11–6574—0022–0025); TALDF Lawyer 3 Legal Service Invoices (‘‘TALDF 

Lawyer 3 Invoices’’) (Exhibit 11 at 11–6574—0074–0161). 26Memorandum of Interview of Representative Schmidt’s Chief of Staff, April 6, 2011 (‘‘Chief 

of Staff MOI’’) (Exhibit 12 at 11–6574—0163). 27 Id. at 11–6574—0164. 28 Id. 29TCA President MOI (Exhibit 3 at 11–6574—0012). 30 Id. 31 Id. at 11–6574—0012–0013. 32 Id at 11–6574—0013. 33 Chief of Staff MOI (Exhibit 12 at 11–6574—0165). 34 Id at 11–6574—0164. 35TCA President MOI (Exhibit 3 at 11–6574—0013). 

TALDF and Representative Schmidt 

30. Since 2008, TALDF has provided legal services to Representative Schmidt related to various legal matters between her and Mr. 

David Krikorian.25

31. In 2006 or 2007, Mr. Krikorian visited Representative 

Schmidt’s congressional office in Washington, DC.26 He came to the 

office to meet with Representative Schmidt to request her support 

for the Armenian genocide resolution.27

32. According to Representative Schmidt’s Chief of Staff, Mr. 

Krikorian became belligerent because Representative Schmidt 

would not commit to voting for the resolution.28

33. In November 2007, the TCA President first met Representative Schmidt when he overheard her discussing the Armenian 

genocide resolution at a campaign fundraiser at the Capitol Hill 

Club in Washington, DC.29

34. He introduced himself and offered to provide her with information about the Armenian genocide issue.30

35. The TCA President told the OCE that he saw Representative 

Schmidt frequently in 2008 as she attended various TCA events 

and events with the TCA political action committee.31

36. During the same period in 2008, the TCA President believes 

that he spoke with Representative Schmidt’s Chief of Staff at least 

once per month.32

37. Representative Schmidt’s Chief of Staff explained to the OCE 

that he first met the TCA President when the TCA President visited Representative Schmidt’s office to lobby him on the Armenian 

genocide resolution.33

38. In 2008, Mr. Krikorian ran as an independent candidate 

challenging Representative Schmidt for her congressional seat. 

39. The TCA President recalls that in late spring of 2008, Mr. 

Krikorian circulated an email that criticized Representative 

Schmidt for attending campaign fundraisers with Turkish Americans.34 The TCA President was furious about the email and there 

were internal discussions at TCA about whether TALDF should 

take any legal action in the matter.35

40. During the week before the November 4, 2008 election, Mr. 

Krikorian placed pamphlets on cars outside of Representative 

Schmidt’s church that accused her of various activities, including 
10

36 Chief of Staff MOI (Exhibit 12 at 11–6574—0164). 37TALDF Requests Criminal Investigation in Ohio, November 3, 2008, http://www.taldf.org/

ohio.html (Exhibit 14 at 11–6574—0172). 38TALDF Lawyer 1 MOI (Exhibit 2 at 11–6574—0007). 39TALDF Lawyer 1 RFI Response (Exhibit 7 at 11–6574—0030); TALDF Lawyer 2 RFI Response (Exhibit 9 at 11–6574—0060–0061); TALDF Lawyer 3 RFI Response (Exhibit 5 at 11– 

6574—0022–0023). 40Jean Schmidt v. Mr. David Krikorian, Ohio Election Commission Case No. 2009E–003, 

April 29, 2009 (‘‘Initial OEC Complaint’’) (Exhibit 15 at 11–6574—0175–0178). 41TALDF Lawyer 2 Invoices (Exhibit 10 at 11–6574—0065); TALDF Lawyer 3 Invoices (Exhibit 11 at 11–6574—0074–0075). 42TALDF Lawyer 1 and TALDF Lawyer 2 sent the bills for their legal services directly to 

TCA and TALDF Lawyer 3 sent his bills to TALDF. See TALDF Lawyer 1 Invoices (Exhibit 8 

at 11–6574—0033–0057); TALDF Lawyer 2 Invoices (Exhibit 10 at 11–6574—0065–0075); 

TALDF Lawyer 3 Invoices (Exhibit 11 at 11–6574—0074–0161). TCA paid the bills. TCA President MOI (Exhibit 3 at 11–6574—0012). 43TALDF Lawyer 2 Invoices (Exhibit 10 at 11–6574—0065); TALDF Lawyer 3 Invoices (Exhibit 11 at 11–6574—0076–0077). 44TCA President MOI (Exhibit 3 at 11–6574—0012). 45 Initial OEC Complaint (Exhibit 15 at 11–6574—0175–0178). 46Jean Schmidt v. Mr. David Krikorian, Ohio Election Commission Case No. 2009E–012, July 

21, 2009 (Exhibit 16 at 11–6574—0180–0182). 

accepting ‘‘blood money’’ from the Turkish Government to deny the 

Armenian genocide.36

41. On November 3, 2008, TALDF posted on its website a statement that it ‘‘requested the Attorney General of Ohio, Nancy H. 

Rogers, to open a criminal investigation under Ohio law into signature Armenian verbal thuggery employed by Armenian American 

independent candidate David Krikorian against Representative 

Jean Schmidt.’’ 37

42. TALDF Lawyer 1 remembered that his first meeting with 

Representative Schmidt about providing legal services occurred in 

her congressional office in late November 2008.38

2008 Legal Services 

43. According to the TALDF lawyers, TALDF first provided legal 

services for Representative Schmidt in her case against Mr. 

Krikorian before the Ohio Election Commission.39 She alleged in 

the case that Mr. Krikorian made false statements about her during the 2008 campaign that violated the Ohio state law prohibiting 

unfair political campaign activities.40

44. The TALDF lawyers began working on this matter in late 

2008.41 The lawyers billed their legal services on behalf of Representative Schmidt to TCA.42

45. The amount of fees and expenses and legal services for 2008 

was approximately $3,905.43

46. TCA paid the TALDF lawyers for the legal services performed on behalf of Representative Schmidt.44

2009 Legal Services 

47. In early 2009, the TALDF lawyers prepared Representative 

Schmidt’s complaint for the Ohio Election Commission matter, 

which they filed on April 29, 2009.45

48. The lawyers filed an additional complaint with the Ohio 

Election Commission on behalf of Representative Schmidt on July 

21, 2009.46
11

47Letters from Ohio Election Commission to Bruce Fein, dated November 13, 2009 (Exhibit 

17 at 11–6574—0184–0187). 48TALDF Lawyer 1 RFI Response (Exhibit 7 at 11–6574—0030); TALDF Lawyer 2 RFI Response (Exhibit 9 at 11–6574—0061); TALDF Lawyer 3 RFI Response (Exhibit 5 at 11–6574— 

0023). 49TALDF Lawyer 1 and TALDF Lawyer 2 sent the bills for their legal services directly to 

TCA and TALDF Lawyer 3 sent his bills to TALDF. TALDF Lawyer 1 Invoices (Exhibit 8 at 

11–6574—0033–0057); TALDF Lawyer 2 Invoices (Exhibit 10 at 11–6574—0065–0072); TALDF 

Lawyer 3 Invoices (Exhibit 11 at 11–6574—0074–0161). TCA paid the bills. See TCA President 

MOI (Exhibit 3 at 11–6574—0012). 50TALDF Lawyer 1 Invoices (Exhibit 8 at 11–6574—0033–0044);TALDF Lawyer 2 Invoices 

(Exhibit 10 at 11–6574—0066–0069); TALDF Lawyer 3 Invoices (Exhibit 11 at 11–6574—0078– 

0116); TCA Legal Expenses for 2009 and 2010 (‘‘TCA Legal Expenses’’) (Exhibit 18 at 11–6574— 

0189). 51See TCA President MOI (Exhibit 3 at 11–6574—0012). 52David Krikorian v. Ohio Elections Commission, et al., S.D. Ohio Civ., Motion of Amicus Curiae Jean Schmidt for Leave to File an Amicus Brief in Support of Defendants’ Opposition to 

Plaintiff’s Motion for Temporary Restraining Order and Preliminary Injunction, dated February 

21, 2010. 53TALDF Lawyer 2 RFI Response (Exhibit 9 at 11–6574—0062). 54 Id. 55 Id. 56 Id.; Jean Schmidt v. David Krikorian and Krikorian for Congress Campaign Committee, 

Court of Common Pleas Clermont County, Ohio, Case No. 2010 CVC1217, June 8, 2010 (Exhibit 

19 at 11–6574—0191–0223). 57TALDF Lawyer 2 RFI Response (Exhibit 9 at 11–6574—0062). 58TALDF Lawyer 1 and TALDF Lawyer 2 sent the bills for their legal services directly to 

TCA and TALDF Lawyer 3 sent his bills to TALDF. TALDF Lawyer 1 Invoices (Exhibit 8 at 

11–6574—0033–0057); TALDF Lawyer 2 Invoices (Exhibit 10 at 11–6574—0065–0072); TALDF 

Continued

49. On October 1, 2009, the Ohio Election Commission found in 

favor of Representative Schmidt, concluding that Mr. Krikorian 

made false statements about her.47

50. In 2009, the lawyers also represented Representative 

Schmidt in Mr. Krikorian’s appeals of the Ohio Election Commission decision.48

51. The TALDF lawyers billed their 2009 legal services on behalf 

of Representative Schmidt to TCA. 49

52. The amount of fees and expenses and legal services for 2009 

was approximately $289,280.50

53. TCA paid the TALDF lawyers for the 2009 legal services performed on behalf of Representative Schmidt.51

2010 Legal Services 

54. On February 21, 2010, the TALDF lawyers filed a Motion for 

Leave to file an Amicus Brief on behalf of Representative Schmidt 

in a federal lawsuit that Mr. Krikorian brought against the Ohio 

Election Commission in the Southern District Court of Ohio.52 The

suit challenged whether the Ohio Election Commission had the 

right to make its findings in the 2009 matters concerning Representative Schmidt.53 Representative Schmidt was not named as 

a party to the lawsuit.54

55. The TALDF lawyers later filed an amicus brief on behalf of 

Representative Schmidt in the case.55

56. On June 8, 2010, the TALDF lawyers filed a defamation lawsuit on behalf of Representative Schmidt against Mr. Krikorian. 

Representative Schmidt seeks $6.8 million dollars in damages.56

57. Mr. Krikorian’s federal lawsuit against the Ohio Election 

Commission was dismissed on October 19, 2010.57

58. The TALDF lawyers billed their 2010 legal services on behalf 

of Representative Schmidt to TCA.58
12

Lawyer 3 Invoices (Exhibit 11 at 11–6574—0117–0161). TCA paid the bills. See TCA President 

MOI (Exhibit 3 at 11–6574—0012). 59TALDF Lawyer 1 Invoices (Exhibit 8 at 11–6574—0045–0057);TALDF Lawyer 2 Invoices 

(Exhibit 10 at 11–6574—0070–0072); TALDF Lawyer 3 Invoices (Exhibit 11 at 11–6574—0117– 

0161); TCA Legal Expenses (Exhibit 18 at 11–6574—0189). 60See TCA President MOI (Exhibit 3 at 11–6574—0012). 61TALDF Lawyer 1 RFI Response (Exhibit 7 at 11–6574—0030). 62 Id.; See TCA President MOI (Exhibit 3 at 11–6574—0012). 63 Representative Schmidt MOI (Exhibit 13 at 11–6574—0169); Chief of Staff MOI (Exhibit 

12 at 11–6574—0165–0166). 64 Chief of Staff MOI (Exhibit 12 at 11–6574—0164). 65Deposition of Barry P. Bennett, dated August 31, 2009 (Exhibit 20 at 11–6574—0247). 66 Id. 67Letter from Representative Schmidt to Chairwoman Zoe Lofgren, dated September 17, 2009 

(Exhibit 21 at 11–6574—0270). 68Letter from Chair Lofgren and Ranking Member Bonner to Representative Schmidt, dated 

February 26, 2010 (‘‘Advisory Opinion’’) (Exhibit 22 at 11–6574—0273). 69Letter from Chair Lofgren and Ranking Member Bonner to Representative Schmidt, dated 

February 26, 2010 (‘‘Advisory Opinion’’) (Exhibit 22 at 11–6574—0274). 

59. The amount of fees and expenses and legal services for 2010 

was approximately $205,401.59

60. TCA paid the TALDF lawyers for the 2010 legal services performed on behalf of Representative Schmidt.60

2011 Legal Services 

61. Representative Schmidt’s defamation lawsuit against Mr. 

Krikorian continues in 2011.61

62. The TALDF lawyers are currently providing legal services 

and TCA is paying for the legal services.62

C. REPRESENTATIVE SCHMIDT RECEIVED AN ADVISORY OPINION FROM 

THE COMMITTEE IN 2010 

63. Representative Schmidt did not request an advisory opinion 

from the Committee prior to the TALDF lawyers providing her 

legal services in 2008.63

64. Representative Schmidt’s Chief of Staff told the OCE that he 

spoke with staff at the Committee in early 2009 about how to pay 

for the legal services.64

65. On August 31, 2009, Representative Schmidt’s Chief of Staff 

was deposed in the matter before the Ohio Election Commission. 

He was asked whether he had ‘‘made some kind of filing with the 

House Ethics Committee that would allow the Turkish American 

Legal Defense Fund to fund this legal action against Mr. 

Krikorian.’’ 65 Representative Schmidt’s Chief of Staff answered 

that he had not made such a filing.66

66. On September 17, 2009, Representative Schmidt wrote a letter to the Committee ‘‘to seek guidance regarding the payment of 

legal fees associated with a case in which my campaign and I are 

now involved.’’ 67

67. On January 21, 2010, Representative Schmidt amended her 

request for guidance ‘‘due to changed circumstances’’ since the 

original letter.68

68. On February 26, 2010, the Committee provided Representative Schmidt with an advisory opinion. The scope of the advice is 

limited to payments for two legal matters, which are ‘‘legal work 

already completed during the [Ohio] Elections Commission proceedings, and future legal work on [Representative Schmidt] behalf 

in the appellate case in Ohio Court.’’ 69
13

70 Id. at 11–6574—0273. 71 Id. at 11–6574—0277. 72 Id. at 11–6574—0279. 73 Id. 74 Id. at 11–6574—0277(emphasis added). 75 Id. at 11–6574—0274. 76 Id.

69. The Committee advised that ‘‘the establishment of a legal expense fund and the use of campaign funds are both permissible options for payment of legal expenses in connection with both past 

and future proceedings, subject to the limitations [in the advisory 

opinion].’’ 70

70. The Committee also advised that ‘‘before you may begin accepting or soliciting for donations to cover past and future legal expenses as described above, the Committee must approve your proposed trust agreement.’’ 71

D. RELEVANT AND MATERIAL INFORMATION MAY NOT HAVE BEEN PROVIDED TO THE COMMITTEE CONCERNING THE NATURE OF THE LEGAL 

SERVICES

71. The advisory opinion from the Committee to Representative 

Schmidt states that the ‘‘Committee will take no adverse action 

against you in regard to any conduct that you undertake, or have 

undertaken, in good faith reliance upon this advisory opinion, so

long as you have presented a complete and accurate statement of all 

material facts relied upon, herein, and the proposed conduct in 

practice conforms with the information you provided, as addressed 

in this opinion.’’ 72

72. In the advisory opinion, the Committee also reserved the 

right to rescind, modify, or terminate the opinion: ‘‘However, the 

Committee will rescind an advisory opinion if relevant and material facts were not completely and accurately disclosed to the Committee at the time the opinion was issued.’’ 73

73. Pursuant to the advisory opinion, ‘‘[t]here is no restriction 

under the Committee’s Legal Expense Fund Regulations that 

would bar the establishment of such a trust fund to pay past legal 

expenses, so long as no solicitation or receipt of donations occurred 

before the Committee’s written approval of the trust agreement.’’ 74

74. The advisory opinion relies on facts that Representative 

Schmidt and her staff provided concerning the prior payments of 

the legal expenses. 

TCA Paid for Representative Schmidt’s Legal Services Prior 

to Written Approval of a Legal Expense Fund 

75. In the advisory opinion, the Committee indicated that it was 

under the impression that Representative Schmidt’s attorneys had 

worked approximately 200 hours and have not billed Representative Schmidt or received any payments for their services.75

76. The advisory opinion mentions that ‘‘[t]o date, Mr. Fein estimates that 200 hours have been worked by the attorneys in your 

case, but you have not yet been billed as you are awaiting this 

Committee’s guidance regarding the permissibility of the proposed 

options for payment of legal expenses in this matter.’’ 76

77. The following relevant and material information appears not 

to have been provided to the Committee as of the date of the advisory opinion: (1) Representative Schmidt’s lawyers had worked 
14

77TALDF Lawyer 1 Invoices (Exhibit 8 at 11–6574—0033–0044); TALDF Lawyer 2 Invoices 

(Exhibit 10 at 11–6574—0065–0069); TALDF Lawyer 3 Invoices (Exhibit 11 at 11–6574—0076– 

0116). 78TALDF Lawyer 1 and TALDF Lawyer 2 sent the bills for their legal services directly to 

TCA and TALDF Lawyer 3 sent his bills to TALDF. See TALDF Lawyer 1 Invoices (Exhibit 8 

at 11–657—0033–0057) TALDF Lawyer 2 Invoices (Exhibit 10 at 11–6574—0065–0072); TALDF 

Lawyer 3 Invoices (Exhibit 11 at 11–6574—0074–161). 79TALDF Lawyer 1 Invoices (Exhibit 8 at 11–6574—0033–0044); TALDF Lawyer 2 Invoices 

(Exhibit 10 at 11–6574—0065–0069); TALDF Lawyer 3 Invoices (Exhibit 11 at 11–6574—0076– 

0116). 80See TCA President MOI (Exhibit 3 at 11–6574—0012). 81TALDF Lawyer 1 MOI (Exhibit 2 at 11–6574—0006); TALDF Lawyer 2 MOI (Exhibit 4 at 

11–6574—0016); TALDF Lawyer 3 RFI Response (Exhibit 5 at 11–6574—0020). 82TALDF Lawyer 1 and TALDF Lawyer 2 sent the bills for their legal services directly to 

TCA and TALDF Lawyer 3 sent his bills to TALDF. See TALDF Lawyer 1 Invoices (Exhibit 8 

at 11–6574—0033–0057); TALDF Lawyer 2 Invoices (Exhibit 10 at 11–6574—0065–0072); 

TALDF Lawyer 3 Invoices (Exhibit 11 at 11–6574—0074–0161). TCA paid the bills. See TCA

President MOI (Exhibit 3 at 11–6574—0012). 83See TCA President MOI (Exhibit 3 at 11–6574—0012). 84TALDF Lawyer 1 MOI (Exhibit 2 at 11–6574—0007). 85 Id.; TALDF Lawyer 2 MOI (Exhibit 4 at 11–6574—0017–0018); TCA President MOI (Exhibit 3 at 11–6574—0012). 86TALDF Lawyer 1 MOI (Exhibit 2 at 11–6574—0007); TALDF Lawyer 2 MOI (Exhibit 4 at 

11–6574—0017–0018). 87TCA President MOI (Exhibit 3 at 11–6574—0012). 88TALDF Lawyer 1 MOI (Exhibit 2 at 11–6574—007–008); TALDF Lawyer 2 MOI (Exhibit 

4 at 11–6574—0018). 89Deposition of Bruce Fein, dated August 31, 2009 (Exhibit 23 at 11–6574—0310). 90TCA President MOI (Exhibit 3 at 11–6574—0012). 91 Id. 92 Id.

more than 500 hours in her cases; 77 (2) Representative Schmidt’s 

lawyers sent their bills to TCA; 78 and (3) TCA had paid Representative Schmidt’s lawyers approximately $293,000 for services received in 2008 and 2009.79

78. The President of TCA told the OCE that TCA pays all of the 

legal expenses for TALDF from its general operating account.80

79. The TALDF lawyers are employed by separate law firms.81

Each law firm submits its legal bills to TCA.82

80. TCA pays for the legal fees and expenses for each attorney 

performing legal services for Representative Schmidt.83

81. TALDF provides free legal services to all of its clients.84 TCA

pays the TALDF lawyers for their services.85

TCA Has Not Sought Reimbursement from Representative 

Schmidt

82. TALDF Lawyer 1 and TALDF Lawyer 2 explained to the 

OCE that they never send bills to TALDF clients.86 TCA pays for 

their legal fees.87

83. TALDF Lawyer 1 and TALDF Lawyer 2 told the OCE that 

they were under the impression that they were providing their 

legal services at no cost to Representative Schmidt.88

84. TALDF Lawyer 1 testified in a deposition during the matter 

before the Ohio Election Commission that he told Representative 

Schmidt and her campaign that ‘‘we would not charge them legal 

fees.’’ 89

85. The TCA President told the OCE that he does not bill anyone for the payments that TCA gives to TALDF.90 TCA has never 

sought reimbursement for such expenses.91

86. The TCA President explained that he has not had conversations with Representative Schmidt about payments for the legal 

services.92
15

93 Representative Schmidt MOI (Exhibit 13 at 11–6574—0169). 94TALDF Lawyer 1 Invoices (Exhibit 8 at 11–6574—0033–0057); TALDF Lawyer 2 Invoices 

(Exhibit 10 at 11–6574—0065–0072); TALDF Lawyer 3 Invoices (Exhibit 11 at 11–6574—0074– 

0161); TCA Legal Expenses (Exhibit 18 at 11–6574—0189). 95TALDF Lawyer 1 Invoices (Exhibit 8 at 11–6574—0033–0057); TALDF Lawyer 2 Invoices 

(Exhibit 10 at 11–6574—0065–0072); TALDF Lawyer 3 Invoices (Exhibit 11 at 11–6574—0074– 

0161); TCA Legal Expenses (Exhibit 18 at 11–6574—0189). 96TALDF Lawyer 1 MOI (Exhibit 2 at 11–6574—0007–0008); TALDF Lawyer 2 MOI (Exhibit 

4 at 11–6574—0017). 97TCA President MOI (Exhibit 3 at 11–6574—0012). 98TALDF Lawyer 1 RFI Response (Exhibit 7 at 11–6574—0030). 99TCA President MOI (Exhibit 3 at 11–6574—0013); TALDF Lawyer 1 MOI (Exhibit 2 at 11– 

6574—0007). 100TCA President MOI (Exhibit 3 at 11–6574—0012). 101 Advisory Opinion (Exhibit 22 at 11–6574—0275). Under the Legal Expense Fund Regulations, pro bono legal services are considered to be contributions to a legal expense fund and 

thereby cannot be accepted without the Committee’s written approval of the trust document. 

Legal Expense Fund Regulations (Exhibit 1 at 11–6574—0002–0004). The Legal Expense Fund 

Regulations allow the acceptance of pro bono legal services under the following limited circumstances: ‘‘to file an amicus brief in his or her capacity as a Member of Congress; to bring 

a civil action challenging the validity of any federal law or regulation; or to bring a civil action 

challenging the lawfulness of an action of a federal agency, or an action of a federal official 

taken in an official capacity, provided that the action concerns a matter of public interest, rather 

than a matter that is personal in nature.’’ Id. at 11–6574—0003. 

87. Representative Schmidt told the OCE that TALDF did not 

offer to provide her free legal services and that she discussed the 

possibility of a contingency fee, but that option was not pursued.93

Her statements are not consistent with the statements of the 

TALDF lawyers and TCA President about payments for the legal 

services.

E. TCA HAS PAID APPROXIMATELY $500,000 TO THREE LAW FIRMS FOR 

THE LEGAL SERVICES PROVIDED TO REPRESENTATIVE SCHMIDT 

88. The TALDF lawyers provided the OCE with statements for 

legal fees and expenses that they billed for Representative 

Schmidt’s legal matters from 2008 through the December 2010.94

89. Based on these invoices, the lawyers charged legal fees and 

expenses totaling approximately $498,587.95

90. According to the lawyers, they have received payment for the 

fees and expenses.96 According to the TCA President, TCA paid for 

these expenses.97

91. Representative Schmidt’s defamation suit against Mr. 

Krikorian is ongoing in 2011 and the TALDF lawyers are representing her in this matter.98

92. Representative Schmidt has not received any invoice for 

these services and TCA never intended to send her an invoice for 

these services.99 TCA paid for the services out of its general operating budget in the same manner that it pays for all TALDF clients.100

F. REPRESENTATIVE SCHMIDT ACCEPTED ADDITIONAL LEGAL SERVICES 

AFTER RECEIVING THE ADVISORY OPINION 

93. As mentioned above, on February 26, 2010, the Committee 

provided Representative Schmidt with a written opinion advising 

that she could pay for the TALDF legal services by either establishing a legal expense fund or using campaign funds. 

94. With respect to establishing the legal expense fund, the Committee advised Representative Schmidt that ‘‘[n]o contribution may 

be solicited for or accepted by a fund prior to the Committee’s written approval of the completed trust document and the trustee.’’ 101
16

102Letter from Representative Schmidt to Chair Lofgren and Ranking Member Bonner, dated 

July 19, 2010 (‘‘Request for Legal Expense Fund Approval’’) (Exhibit 24 at 11–6574—0389). 103Jean Schmidt v. David Krikorian and Krikorian for Congress Campaign Committee, Court

of Common Pleas Clermont County, Ohio, Case No. 2010 CVC1217, June 8, 2010 (Exhibit 19 

at 11–6574—0191–0222). 104TALDF Lawyer 1 RFI Response (Exhibit 7 at 11–6574—0030; TCA President MOI (Exhibit 

3 at 11–6574—0012). 105 Request for Legal Expense Fund Approval (Exhibit 24 at 11–6574—0389). 106Letter from Representative Schmidt to Chair Lofgren and Ranking Member Bonner, dated 

August 11, 2010 (Exhibit 25 at 11–6574—0391–0392). 107 Email from Heather Jones to Joe Jansen, dated August 26, 2010 (Exhibit 26 at 11–6574— 

0394). 108Proposed Contingency Agreement between TALDF and Representative Schmidt, dated August 26, 2010 (Exhibit 27 at 11–6574—0396). 109TALDF Lawyer 1 MOI (Exhibit 2 at 11–6574—0007–0008). 110 Id. at 11–6574—0007. 111 Id. 112 Id.

95. After receiving the February 26, 2010 advisory opinion, Representative Schmidt did not submit a request for approval of a 

legal expense fund until July 19, 2010.102

96. On June 8, 2010, Representative Schmidt filed a defamation 

lawsuit against Mr. Krikorian seeking $6.8 million in damages.103

97. The TALDF lawyers represent her in this matter and TCA 

pays their legal fees.104

Request for Approval of Legal Expense Fund 

98. On July 19, 2010, Representative Schmidt wrote a letter to 

the Committee requesting approval of a legal expense fund.105

99. On August 11, 2010 Representative Schmidt requested that 

the Committee approve a contingency fee agreement in connection 

with the $6.8 million defamation lawsuit.106

100. She also requested permission to use a legal expense fund 

to pay for legal services that the TALDF provided in connection 

with the amicus brief filed in Ohio federal court in February 2010. 

Request for Approval of Contingency Fee Agreement 

101. On August 26, 2010 the Committee requested that Representative Schmidt provide a copy of the proposed contingency fee 

agreement for the defamation lawsuit.107 Although the lawsuit was 

filed on June 8, 2010, the proposed contingency fee agreement is 

dated August 26, 2010.108 Based on the information before the 

OCE, a final contingency fee agreement was not executed. 

102. TALDF Lawyer 1, who signed the August 26 proposed contingency fee agreement, told the OCE that the TALDF legal services for the defamation suit are not part of a contingency fee agreement.109 The services are provided pro bono similar to the other 

legal services TALDF has provided to Representative Schmidt.110

103. He explained that he and the other lawyers will not receive 

any part of a monetary judgment from the defamation suit. If damages are awarded, half of the award is for Representative Schmidt 

and the other half is for TCA.111 The TALDF lawyers are paid 

whether or not there are damages awarded in the matter. 

104. As result, the TALDF lawyers’ payment is not contingent 

on the outcome of the case. TCA pays the lawyers based on the 

hours billed for work on Representative Schmidt’s matter.112
17

113 Representative Schmidt Amended Calendar Year 2009 Financial Disclosure Statement, 

dated July 15, 2010 (Exhibit 28 at 11–6574—0398). 114 Representative Schmidt Amended Calendar Year 2008 Financial Disclosure Statement, 

dated May 13, 2009 (Exhibit 28 at 11–6574—0398); Representative Schmidt Amended Calendar 

Year 2009 Financial Disclosure Statement, dated July 15, 2010 (Exhibit 29 at 11–6574—0411). 115Legal Expense Fund Regulations (Exhibit 1 at 11–6574—0002); House Ethics Manual 63– 

65.116 Id. 117 Id. The Legal Expense Fund Regulations allow the acceptance of pro bono legal services 

under the following limited circumstances. See supra note 101. 118Letter from Chair Zoe Lofgren and Ranking Member Jo Bonner to Representative Charles 

B. Rangel, dated October 29, 2010 (Exhibit 30 at 11–6574—0432). The Board notes that this 

advisory opinion to Representative Rangel was issued only to him and cannot be relied upon 

by any other individual or entity. The letter is cited here only as an example of the application 

of the Legal Expense Fund Regulations. 119 Id.

G. REPRESENTATIVE SCHMIDT DID NOT DISCLOSE THE LEGAL SERVICES 

SHE RECEIVED ON HER FINANCIAL DISCLOSURE STATEMENTS FOR CALENDAR YEARS 2008 AND 2009 

105. Representative Schmidt filed her Calendar Year 2008 Financial Disclosure Statement on May 13, 2009. 

106. Representative Schmidt answers ‘‘No’’ to the question ‘‘Did 

you, your spouse, or a dependent child receive any reportable gift 

in the reporting period (i.e., aggregating more than $335 and not 

otherwise exempt)?’’ 113

107. Representative Schmidt filed her Calendar Year 2009 Financial Disclosure Statement on May 15, 2010. On July 15, 2010, 

she amended the filing. 

108. In the original and amended statements, Representative 

Schmidt answers ‘‘No’’ to the question ‘‘Did you, your spouse, or a 

dependent child receive any reportable gift in the reporting period 

(i.e., aggregating more than $335 and not otherwise exempt)?’’ 114

III. CONCLUSION 

109. The Committee issued detailed guidance explaining the 

steps that Members must follow to solicit or receive donations to 

pay legal expenses.115

110. The Legal Expense Fund Regulations require that a Member first receive approval to establish a legal expense fund before 

receiving cash or in-kind donations (e.g., pro bono legal services).116

111. The Legal Expense Fund Regulations state that pro bono 

legal services are contributions to a legal expense fund and cannot 

be accepted without the Committee’s written approval of a legal expense fund.117

112. For example, the Committee recently responded to a Member’s request for approval to accept pro bono legal services.118 The

Committee advised the Member that ‘‘it would not be permissible 

for you to solicit or accept pro bono or reduced-fee legal representation in connection with the ongoing disciplinary proceedings, absent 

the establishment of a legal expense fund for such purpose.’’ 119

113. In this review, TCA and TALDF told the OCE that legal 

services were provided to Representative Schmidt on a pro bono 

basis.

114. TCA has paid approximately $500,000 to three law firms for 

legal services provided to Representative Schmidt in 2008, 2009, 

2010, and 2011. 
18

115. Representative Schmidt did not receive permission from the 

Committee to establish a legal expense fund prior to accepting the 

legal services. Representative Schmidt told the OCE that she has 

submitted a request to the Committee for approval of a legal expense fund. 

116. The Board is not aware of the status of Representative 

Schmidt’s request for approval of the legal expense fund. However, 

even if a legal expense fund is approved, TCA has already paid for 

the legal services and does not seek reimbursement. 

117. In conclusion, the Board finds that there is substantial reason to believe that Representative Schmidt violated House Rule 25, 

clause 3 by accepting legal services from TALDF, which TCA paid 

for prior to her receiving approval from the Committee of a legal 

expense fund. 

118. The Board also finds that there is substantial reason to believe that Representative Schmidt violated House Rule 26, clause 

2 and the Ethics in Government Act by failing to report that she 

received legal services from TALDF as gifts on her financial disclosure statements for calendar years 2008 and 2009. 

119. For these reasons, the Board recommends that the Committee further review the allegations described above concerning 

Representative Schmidt. 
19

EXHIBIT 1 

21

394 HOUSE ETHICS MANUAL 

Legal Expense Fund Regulations 

MEMORANDUM TO ALL MEMBERS, OFFICERS, AND EMPLOYEESl 

From: Committee on Standards of Official Conduct 

Nancy L. Johnson, Chairman 

Jim McDermott, Ranking Democratic Member 

Date: June 10, 1996 

The new gift rule exempts "a contribution or other payment to a legal 

expense fund established for the benefit of a Member, officer, or employee that is 

otherwise lawfully made in accordance with the restrictions and disclosure 

requirements of the Committee on Standards of Official Conduct," as long as the 

contribution is not from a registered lobbyist or an agent of a foreign principal 

(House Rule 25, clause 5(a)(3)(E)). In light of this new rule, and pursuant to its 

authOl'ity there under, the Committee hereby issues regulations explaining its 

"restrictions and disclosure requirements" for legal expense funds. The regulations 

set forth below supersede the Committee's prior policies under the old gift rule" and 

take effect as of July 1, 1996. The prior policies remain in effect until that date. 

Legal Expense Fund Regulations 

1. A Member, officer, or employee who wishes to solicit andlor receive donations, 

in cash or in kind, to pay legal expenses shall obtain the prior written 

permission of the Committee on Standards of Official Conducta 

2. The Committee shall grant permission to establish a Legal Expense Fund 

only where the legal expenses arise in connection with: the individual's 

candidacy for or election to federal office; the individual's official duties or 

position in Congress (including legal expenses incurred in connection with an 

amicus brief filed in a Member's official capacity, a civil action by a Member' 

challenging the validity of a law or federalr'egulation, or a matter' before the 

Committee on Standards of Official Conduct); a criminal prosecution; or a 

civil matter bearing on the individual's reputation or fitness for office. 

1 These regulations have been updated in several respects. including to reflect certain 

Committee policies established after the regulations were originally issued. and the renumbering of 

the House Hules that occurred at the beginning afthe lOG!11 and 107th Congresses. 

i 5,{'(' How.£! Etilli:::. Jldfl11IWl. 102d Cong .. 2d Sass. 49-50 (1992) . 

.3 Permission is not required to solicit and/or receive a donation in any amount from a relative 

or a donation of up to $2:')0 from a personal friend. 
22

Appendices 395 

3. The Committee shall not grant permission to establish a Legal Expense Fund 

where the legal expenses arise in connection with a matter that is primarily 

personal in natUI'e (e.g:, a matrimonial action). 

4. A Member, officer, or employee may accept pro bono legal assistance without 

limit to file an amicus brief in his or her capacity as a Member of Congress; to 

bring a civil action challenging the validity of any federal law or regulation; 

or to bring a civil action challenging the lawfulness of an action of a fedel'al 

agency, or an action of a federal official taken in an official capacity, provided 

that the action concerns a matter of public interest, rather than a matter that 

is personal in nature. Pro bono legal assistance for other purposes shall be 

deemed a contribution subject to the restrictions of these regulations. 

5. A Legal Expense Fund shall be set up as a trust, administered by an 

independent trustee, who shall oversee fund raising. 

6. The trustee shall not have any family, business, or employment relationship 

with the trust's beneficiary. 

7. Trust funds shall be used only for legal expenses (and expenses incUI'red in 

soliciting for and administering the trust), except that any excess funds shall 

be returned to conh'ibutOl's. Under no circumstances may the beneficimy of a 

Legal Expense Fund convert the funds to any other purpose. 

8. A Legal Expense Fund shall not accept more than $5,000 in a calendm' yem' 

from any individual 01' organization. 

9. A Legal Expense Fund shall not accept any conh'ibution from a registered 

lobbyist 01' an agent of a fOl'eign principal. 

10. Other than as specifically barred by law or regulation, a Legal Expense Fund 

may accept contributions from any individual or organization, including a 

corporation, labor union, or political action committee (PAC). 

11. No contribution shall be solicited for or accepted by a Legal Expense Fund 

prior to the Committee's written approval of the completed trust document 

(including the name of the trustee). No amendment of the trust document is 

effective, and no successor or substitute trustee may be appointed, without 

the Committee's written approval. 

12. Within one week of the Committee's approval of the trust document, the 

beneficiary shall file a copy of the trust document with the Legislative 

Resource Center (B-I06 Cannon House Office Building) for public disclosUI'e. 
23

396 HOUSE ETHICS MANUAL 

13. The beneficiary of a Legal Expense Fund shall report to the Committee on a 

quarterly basis, with a copy filed for public disclosure at the Legislative 

Resource Center: 

a) any donation to the Fund from a corporation or labor union; 

b) any contribution (or group of contributions) exceeding $250 in a 

calendar year from any other single source; and 

c) any expenditure from the Fund exceeding $250 in a calendar year. 

The reports shall state the full name and street address of each donor, 

contributor or recipient required to be disclosed. Beginning October 30, 1996, 

these reports shall be due as follows: 

Reporting Period 

January 1 - March 31 

April 1 - June 30 

July 1 - September 30 

October 1 - December 31 

Due Date 

April 30 

July 30 

October 30 

January 30 

14. Any Member or employee who established a Legal Expense Fund prior to 

July 1, 1996 shall make any necessary modifications to the trust document to 

bring it into compliance with these regulations and shall disclose the trust 

document with his or her first quarterly report of the 105th Congress on 

January 30, 1997. Reports of receipts and expenditures shall be due 

beginning October 30, 1996, as stated in paragraph 13, above. 

Use of Campaign Funds for Legal Expenses 

This Committee has stated (in Chapter 4 on campaign activity) that Members 

may use campaign funds to defend legal actions ar'ising out of their campaign, 

election, or' the perfOI'mance of their official duties. More recently, however, the 

Federal Election Commission (FE C) issued regulations defining imper'missible 

personal uses of campaign funds, including using campaign funds for certain legal 

expenses. Any Member contemplating the use of campaign funds for the direct 

payment of legal expenses or for contribution to a legal expense fund should first 

contact the FEC. 

25

EXHIBIT 2 

27

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the I 10th Congress as Amended 

INRE: 

REVIEW No .. 

DATE 

LOCATION 

TIME: 

PARTICIPANTS 

OFFICE OF CONGRESSIONAL ETHICS 

UNITED STATES HOUSE OF REPRESENTATIVES 

MEMORANDUM OF INTERVIEW 

T ALDF Lawyer I 

11-6574 

March 28, 20 II 

Bruce Fein & Associates, Inc. 

1025 Connecticut Avenue, NW 

Washington, DC 20036 

10:00 a.m. to 10:45 a.m. (approximately) 

Kedric L. Payne 

Paull Solis 

SUMMARY: The OCE requested an interview TALDF Lawyer I, who is an attorney with the 

Turkish American Legal Defense Fund ("T ALDF"), on March 28, 20 I I, and he consented to an 

interview. T ALDF Lawyer I (the "witness") made the following statements in response to our 

questioning: 

I. The witness was given an 18 US.C § 100 I warning and consented to an interview. He 

signed a written acknowledgement of the warning, which will be placed in the case file in 

thi s revi ew. 

2. The witness explained that TALDF is a unit of the Turkish Coalition of America 

("TCA"). The witness believes that TCA was established in 2005 or 2006 and TALDF 

was established in 2007 or 2008. 

3. His firm, Bruce Fein & Associates, Inc. is his current employer. TCA pays the firm for 

the work that the witness performs on behalf of T ALDF. The witness explained that he 

is more like an independent contractor with TALDF. 

4. TALDF was created to protect the legal rights of Turkish Americans and focuses on free 

speech cases. TALDF receives various requests from individuals requesting legal 

services. 

5. The witness screens potential cases and determines if the cases are consistent with the 

T ALDF mission. 

MOl - Page 1 of4 OFFICE OF CONGRESSIONAL ETHICS 
28

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the I 10th Congress as Amended 

6. The witness told the OCE that a case usually aligns with the TALDF mission ifit 

supports Turkish Americans being able to participate in open public discourse and 

protects Turkish Americans from any type of discrimination. 

7. TCA funds TALDF. As a result, the witness' law firm bills TCA for the hours he works 

on behalf of T ALDF and TCA pays the law firm. There is no retainer agreement and the 

bills are based on the amount oftime the witness spends working on a matter. 

8. T ALDF provides legal services at no charge to its clients, on a "pro hOllo" basis The 

witness stated that its customary to think pro bOliO, although TCA and the client may 

share damage awards in a specific case. 

9. If there is a legal matter where a TALDF client wins a monetary judgment, the money is 

divided between TCA and the client. Neither the witness nor his T ALDF colleague 

receives any portion of monetary damages awarded in a legal matter. 

10. Examples ofTALDF clients include a professor who has a defamation suit and a student 

who has a ci viI rights case. 

II. T ALDF has not represented any federal, state, or local or public official other than 

Representative Schmidt 

12. The witness believes that he first met Representative Schmidt in November 2008. 

13. He first learned of Representative Schmidt from Lincoln McCurdy, who is the President 

of TCA. Mr. McCurdy told the witness that Representative Schmidt was interested in 

filing a complaint with the Ohio Election Commission against David Krikorian. The 

witness does not know who initiated the contact between Mr. McCurdy and 

Representative Schmidt 

14. Near the end of November 2008, the witness met with Representative Schmidt in her 

Washington, DC office to discuss the complaint. He believes that her current Chief of 

Staff, Joe Jansen and her former Chief of Staff, Barry Bennett attended the meeting. The 

witness believes that Joe Jansen was acting as her lawyer at the time. At the meeting, 

they discussed filing a case with the Ohio Elections Commission. 

15. The witness explained that TALDF's legal services were provided at no charge to 

Representative Schmidt and that was his understanding at their first meeting. 

16. Although the complaint was discussed in November 2008, it was not filed until April 

2009 because T ALDF was waiting for "ethics" approval. 

MOl - Page 2 01'4 OFFICE OF CONGRESSIONAL ETHICS 
29

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the I 10th Congress as Amended 

17. The witness did not know at the time whether "ethics" approval meant approval from a 

congressional entity or the Federal Election Commission. He did not know what aspect 

of the representation had to be approved. 

18. In April 2009, Mr. Bennett told the witness that ethics approval had been received and 

action could be filed because it was approved by ethics. 

19. The witness had been working on the case while waiting for client approval. 

20. The witness hired Donald Brey as local counsel for the Ohio Election Commission 

matter. The witness told the OCE that Representative Schmidt referred Mr. Brey to him. 

TCA pays Mr. Brey's legal fees. 

21. T ALDF represented Representative Schmidt in matters involving Mr. Krikorian's appeal 

of the Ohio Election Commission decision, an amicus brief in federal court, and a 

defamation suit against Mr. Krikorian Representative Schmidt was alerted to all of these 

actions 

22. With all of these matters, the witness understood that TALDF was providing pro bono 

services to Representative Schmidt Further, there was no written agreement for scope of 

services to be provided to Representative Schmidt 

23. He considered each of the matters to be related to the Ohio Election Commission 

complaint that was discussed in the first meeting of November 2008. The defamation 

suit was contemplated at the time of the Ohio Election Commission complaint and at 

other times during discussions with Representative Schmidt 

24. The witness stated that the legal services for the defamation suit are not part of a 

contingency fee agreement The services are pro hOlm like the other services provided 

However, there is an understanding that if there is a monetary judgment, it will be equally 

divided between Representative Schmidt and TCA. The witness will not receive any part 

of a monetary judgment 

25. When asked about a complaint that Representative Schmidt's campaign filed before the 

Federal Election Commission against Mr. Krikorian in 2009, the witness said that he was 

not involved in this matter. 

26. Mr. Bennett mentioned a legal trust fund to the witness, but the witness "does not care 

one way or the other if a fund pays for the legal expenses." He will not receive the 

money, but it will reimburse TCA. The witness stated that the back and forth with ethics 

lawyers over a legal trust fund was "not an inflection point" in the battery of litigation 

MOl - Page 3 of4 OFFICE OF CONGRESSIONAL ETHICS 
30

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the 1 10th Congress as Amended 

This memorandum was prepared on March 29, 2011, based on the notes that the OCE staff 

prepared during the interview with the witness on March 28, 2011. I certify that this 

memorandum contains all pertinent matter discussed with the witness on March 28, 20 II. 

Kedric L. Payne 

Investigative Counsel 

MOl - Page 4 of4 OFFICE OF CONGRESSIONAL ETHICS 
31

EXHIBIT 3 

33

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the I 10th Congress as Amended 

INRE: 

REVIEW No .. 

DATE 

LOCATION 

TIME: 

PARTICIPANTS 

OFFICE OF CONGRESSIONAL ETHICS 

UNITED STATES HOUSE OF REPRESENTATIVES 

MEMORANDUM OF INTERVIEW 

President of Turkish Coalition of America ("TCA") 

11-6574 

April 8, 20 II 

Turkish Coalition of America 

1025 Connecticut Avenue 

Washington, DC 20036 

210 p.m. to 300 p.m. (approximately) 

Kedric L. Payne 

Paull Solis 

SUMMARY: The OCE requested an interview with the President of the Turkish Coalition of 

America ("TCA"), on April 8, 2011, and he consented to an interview. The TCA President (the 

"witness") made the following statements in response to our questioning 

1. The witness was given an 180.S.C. § 1001 waming and consented to an interview. He 

signed a written acknowledgement of the warning, which will be placed in the case file in 

this review 

2. The witness told the OCE that was involved in creating TCA with Dr. Yakin Ayasya. 

TCA was created in February 2007. 

3. TCA is a 501(c)(3) organization that is intended to educate the general public about the 

Turkish American community; empower the Turkish American community; and bridge 

gaps between the general public and the Turkish American community 

4. The organization is divided into several groups: Capitol Hill outreach; community 

outreach; scholarship program; and the Turkish American Legal Defense Fund 

("TALDF"). TCA is also involved in organizing trips for Members of Congress and it 

has a political action committee 

5. The witness is the head of the group involved in Capitol Hill outreach. The group also 

has one full-time employee and one part-time employee. The witness told the OCE that 

he spends about 50% of his time working on congressional outreach. 

6. This group works with the Turkish Caucus, which is comprised of Members of Congress. 

The Capitol Hill outreach group encourages Members to join the Turkish Caucus and it 

provides educational materials to Members concerning Turkey 

MOl - Page 1 01'4 OFFICE OF CONGRESSIONAL ETHICS 
34

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the I 10th Congress as Amended 

7. The Capitol Hill outreach group meets with legislators concerning the Armenian 

genocide resolution. The group also meets with legislators concerning Greek and 

Turkish issues. 

8. The witness told the OCE that no one in TCA's Capitol Hill outreach group is registered 

as a lobbyist. He explained that he is not registered as a lobbyist because he only 

educates legislators. 

9. T ALDF was created in late 2007 or the beginning of 2008. The entity was created 

because Dr. Ayasya wanted an organization to help Turkish Americans that were victims 

of discrimination. 

10. The witness described TALDF as an anti-defamation entity T ALDF becomes involved 

in legal matters when the lawyers identify a case and decide to accept it or when Turkish 

Americans request T ALDF' s legal assistance. 

II. The TCA funds TALDF. The witness approves all TCA payments to TALDF and 

controls the TCA budget. 

12. These approvals include all payments to TALDF lawyers Bruce Fein and David 

Saltzman 

13. The money that TCA uses to pay TALDF comes from TCA's general budget. The 

witness told the OCE that the TCA does not seek any reimbursements or payments from 

T ALDF clients. TCA also does not solicit funds from any other sources to pay for 

TALDF expenses. 

14. The witness is involved in pre-approving new T ALDF legal matters. He attends 

meetings about new matters. The approval decisions are done by a consensus of the 

witness; GuIer Koknar, TCA Vice President; Bruce Fein; David Saltzman; and the TCA 

Chairman Dr. Ayasya. This group meets approximately four times per year to make 

decisions on new matters for TALDF. 

15. The witness believes that he first met Representative Jean Schmidt in November 2007 at 

a fundraiser for Ohio Republicans at the Capitol Hill Club. He attended the fundraiser 

because the TCA PAC made a campaign contribution for the event. 

16. During the event, he overheard Representative Schmidt discussing the Armenian 

genocide resolution. He introduced himself and explained to Representative Schmidt that 

he worked for TCA. He offered to provide her with material concerning the Armenian 

genocide issue. 

MOl - Page 2 01'4 OFFICE OF CONGRESSIONAL ETHICS 
35

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the I 10th Congress as Amended 

17. The witness told the OCE that Representative Schmidt collected information from 

sources representing all sides of the Armenian genocide issue and independently decided 

that she could not support the resolution. He believes that she publicly stated that she 

could not support the Armenian genocide resolution in December 2007. 

18. He believes that near late spring 2008, he received an email, possibly from a Turkish 

American. In the email, David Krikorian criticized Representative Schmidt for attending 

campaign fundraisers with Turkish Americans. This email had been sent to various 

recipients and the witness is not sure who sent it to him 

19. The witness was furious when he read this email because it made him feel that Turkish 

Americans could not participate in the political process like everyone else without being 

criticized 

20. He recalls that in the summer of2008 there were internal discussions at TALDF about 

whether they should take any legal action in the matter. 

21. The witness is not certain ifhe approached Representative Schmidt and offered TALDF 

services or if she asked him whether T ALDF could provide services. 

22. He told the OCE that he saw Representative Schmidt a few times after he received the 

Krikorian email and they discussed news aboutMr. Krikorian. During these discussions, 

the witness may have mentioned T ALDF to Representative Schmidt. 

23. He saw Representative Schmidt frequently in 2008 because Representative Schmidt 

attended TCA events. Also, the TCA PAC was involved in events with Representative 

Schmidt. 

24. The witness also spoke with Representative Schmidt's Chief of Staff, Barry Bennett, at 

least once per month in 2008 and they discussed the Krikorian matter. 

25. The witness recalled Mr. Bennett asking him sometlhing about payment for legal services. 

He explained that he either told Mr. Bennett to reach out to Bruce Fein or he may have 

told Bruce Fein to reach out to Mr. Bennett. When asked ifMr. Bennett discussed a 

contingency fee with him, the witness stated that he did not recall that he did. 

26. The witness told the OCE that before TALDF could proceed with assisting 

Representative Schmidt with filing the complaint with the Ohio Election Commission, 

Mr. Bennett mentioned something about "ethics." 

27. He was not involved in any further discussions about payment for the legal services and 

never talked to Representative Schmidt about payment for services. 

MOl - Page 3 of4 OFFICE OF CONGRESSIONAL ETHICS 
36

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the I 10th Congress as Amended 

This memorandum was prepared on April 11,20 II, based on the notes that the OCE staff 

prepared during the interview with the witness on April 8, 2011. I certify that this memorandum 

contains all pertinent matter discussed with the witness on April 8, 2011. 

Kedric L. Payne 

Investigative Counsel 

MOl - Page 4 of4 OFFICE OF CONGRESSIONAL ETHICS 
37

EXHIBIT 4 

39

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the I 10th Congress as Amended 

INRE: 

REVIEW No .. 

DATE 

LOCATION 

TIME: 

PARTICIPANTS 

OFFICE OF CONGRESSIONAL ETHICS 

UNITED STATES HOUSE OF REPRESENTATIVES 

MEMORANDUM OF INTERVIEW 

T ALDF Lawyer 2 

11-6574 

March 28, 2011 

Saltzman & Evinch, P.c. 

655 15th Street, ~W 

Washington, DC 20005 

205 p.m. to 245 a.m. (approximately) 

Kedric L. Payne 

Paull Solis 

SUMMARY: The OCE requested an interview with TALDF Lawyer 2, who is an attorney with 

the Turkish American Legal Defense Fund ("TALDF"), on March 28, 20 II, and he consented to 

an interview. T ALDF Lawyer 2 (the "witness") made the following statements in response to 

our questioning: 

I. The witness was given an 18 US.C § 100 I warning and consented to an interview. He 

signed a written acknowledgement of the warning, which will be placed in the case file in 

thi s revi ew. 

2. The witness is a principle at the law firm of Saltzman & Evinch, P.c. He has been 

employed with the firm since 1993. 

3. He provides legal services to the Turkish American Legal Defense Fund ("TALDF"). 

The services include informing Turkish Americans of their legal rights and reviewing 

requests for legal representation from Turkish Americans. This litigation part of the work 

is what the witness does most of the time for TALDF. 

4. The T ALDF selects legal matters based on whether the cases are within its mission Also 

approval from the Turkish Coalition of America ("TCA") was needed before TALDF 

could accept a legal matter. 

5. The witness told the OCE that he is ajunior litigator for TALDF and Bruce Fein is the 

senior litigator. 

6. The witness has been with T ALDF since it began in 2008. 

MOl - Page 1 of3 OFFICE OF CONGRESSIONAL ETHICS 
40

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the I 10th Congress as Amended 

7. He believes that TALDF' s first litigation matter was a complaint that was filed on behalf 

of Representative Schmidt against David Krikorian in early 2009. 

8. The witness explained that he bills TCA for his legal services, quarterly based on the 

number of hours worked and TCA then makes payments to Saltzman & Evinch, Pc. 

The hourly rate is a negotiated hourly rate. 

9. He believes that he first became aware of the matter involving Representative Schmidt in 

January 2009, when he received a phone call from Bruce Fein. On the call, Mr. Fein told 

the witness that the president ofTCA, Lincoln McCurdy, had a conversation with 

Representative Schmidt about T ADLF representing her in the matter. 

10. The witness first met Representative Schmidt in the spring of2009 at a meeting in her 

office. He was in her office to meet with her then Chief of Staff, Barry Bennett. The 

witness told the OCE that Mr. Bennett was the main point of contact for Representative 

Schmidt's office. 

II. During the spring of 2009, the witness began drafting an outline of a complaint against 

Mr. Krikorian to be filed with the Ohio Election Commission ("OEC"), and then waited 

for approval from Representative Schmidt and TCA. TCA approved the draft complaint 

in February 2009. 

12. The witness stated that it was his impression that TALDF was waiting to file the 

complaint because Representative Schmidt was seeking approval from the House Ethics 

Committee. The witness told the OCE that he believed ethics approval was needed to 

determine if Representative Schmidt could be a plaintiff in a matter and if the legal 

services could be provided at no charge. 

13. The witness stated that at the time, February 2009, TALDF expected no money from 

Representative Schmidt 

14. TALDF filed the complaint with the OEC in April 2009 after Mr. Bennett told Mr. Fein 

that ethics approval had been received. Conversations about ethics issues did not 

continue after this point 

IS. There was no written retainer agreement outlining scope of representation for 

Representative Schmidt. TALDF does not usually enter into written agreements with 

clients expect in one case. 

16. After the OEC issued its decision, Mr. Fein then told the witness to gather his invoices 

for the legal services because Representative Schmidt may reimburse for the expenses. 

However, Representative Schmidt's office never requested the invoices 

MOl - Page 2 of3 OFFICE OF CONGRESSIONAL ETHICS 
41

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the I 10th Congress as Amended 

17. Once fully engaged in the legal matters, TALDF often interacted with Representative 

Schmidt's Chief of Staff. 

18. The witness' involvement in the other matters concerning Representative Schmidt began 

to diminish. He told the OCE that in connection with the OEC complaint, the TALDF 

assisted Representative Schmidt with legal matters related to Mr. Krikorian's attempt at 

appealing the decision, an amicus brief, and a defamation suit. 

19. According to the witness, TALDF understood that all of these legal services were 

provi ded on a pro bOllo basi s. 

20. He also explained that the defamation suit had been contemplated since the initial 

conversation about filing the OEC complaint. The suit was not filed until 20 I 0 because 

T ALDF was monitoring Mr. Krikorian's response to the OEC decision. 

21. The witness did not assist Representative Schmidt with the complaint that her campaign 

filed against Mr. Krikorian before the Federal Election Commission in 2009. 

22. The witness was shown an email concerning "Lawyer Hours on Jean Schmidt Related 

Litigation", (Schmidt_OOIS). He explained that the hours included in the email were 

estimated projections of hours that he would spend on the legal matters. He told the OCE 

that these hours did not rellect actual hours worked. 

This memorandum was prepared on March 31, 2011, based on the notes that the OCE staff 

prepared during the interview with the witness on March 28, 20 II. I certify that this 

memorandum contains all pertinent matter discussed with the witness on March 28, 2011. 

Kedric L. Payne 

Investigative Counsel 

MOl - Page 3 of3 OFFICE OF CONGRESSIONAL ETHICS 

43

EXHIBIT 5 

45

CHESTER 

WILLCOX 

&SA~J1~ COUNSELORS I\T LAW 

Chr:sterWil!cox&Saxba,LlP 

65 East Sla~e SUeet, Suite 1000 

Coll,lmbu~, OH 43215 

MAlrt:614.221_ 

FAX, 614.221.4012 

DONALD C, BREY 

DIRECT: 614.334_ 

-.oocwslaw,com 

February 11, 2011 

Omar S. Ashmawy 

Staff Director and Chief Counsel 

Office of Congressional Ethics 

425 3rd Street, Sw. Suite 1110 

Washington, DC 20024 

Re: January 27, 2011 Request for Informalion 

Dear Mr. Ashmawy: 

Pursuant to your January 27, 2011 Request for Information, enclosed find a CD 

containing the following documents (In Tiff format): 

Bates Number 

DCB_OCE - 0001 through 0002 

DCB_OCE - 0003 through 0006 

DCB_OCE - 0008 through 0009 

DCB_OCE - 00010 through 00095 

Documents 

DCB February 11, 2011 Cover Leiter 

Brief Description of Legal Matters 

Request for Information Certification 

Ledger History 

Redacted Copies of Invoices 

On February 2, 2011, I spoke with Investigative Counsel Kedric Payne, who 

stated that your office is only interested in our redacted bills and the evidence of what 

we were paid for our legal services. Thus, we have redacted from the bills produced the 

detailed description of the work performed. 

While there are many pleadings, transcripts and exhibits that are in the public 

record In the cases in which I have represented Jean Schmidt, my understanding is that 

you are not seeking those documents, but only the documents showing the cost and 

payment for the legal services provided by us. 
46

Omar S. Ashmawy 

February 11, 2011 

Page 2 

Please let me know if I can be of further assistance to your office. 
47

BRIEF DESCRIPTION OF LEGAL MATTERS 

Since 2008, Donald C. Brey and his law firm have appeared on behalf of Jean Schmidt 

before: (I) the Ohio Elections Commission (and administrative appeals from the OEC); (2) 

federal cOUlt; and, (3) Ohio Common Pleas COUlt. All of these appearances related to Jcan 

Schmidt's efforts to protect herself against David Krikorian's decision to knowingly and 

recklessly disseminate falsehoods about Jean Schmidt. 

1. The Ohio Elections Commission F~llsc Statement Cases.-

Two days before the November 4, 2008, general election (at which .lean Sclunidt was 

standing for reelection to Congress), David Krikorian disseminated fliers - including at the 

parking lots of the church where Jean Schmidt worshiped - in which Krikorian said that Jean 

Schmidt was "taking money from a foreign government [Turkey] that is killing our soldiers", 

that "Jean Schmidt has taken $30,000 in blood money from Turkish government sponsored 

political action committees to deny the slaughter of 1.5 million Armenian men, women and 

children by the Ottoman Government during World War II", and that 'This infonnation is public 

record and can be fotllld on the Federal Elections Commission data base" [as this statement 

references facts that support the statements that Turkish government sponsored political action 

committees donated $30,000]. 

Jean Schmidt filed two Complaints before the Ohio Elections Commission regarding 

these statements, pursuant to Ohio Revised Code Section 3517.21(B)(10), which makes it a 

violation to "[p lost, publish, circulate, distribute, or othelwise disseminate a false statement 

concerning a candidate, either know.ing the same to be false or with reckless disregard of whether 

it was false or not, if the statement is designed to promote the election, nomination, or defeat of 

the candidate". The Complaint in OEC Case No. 2009E-003 was filed on April 29, 2009. The 
48

Complaint in ORC Case No. 2009E-012 was filed on July 21, 2009. The two cases were 

consolidated and tried togeth~r. 

The two consolidated Ohio Elections Commission cases were hard fought. David 

Krikorian was represen(ed by experienced Ohio election and first amendment lawyers, as well as 

by prominent lawyers based in Los Angeles and Washington, D,C .. After months of discovery 

(including depositions in Ohio, Washington D.C. and Kentucky), motions, procedural arguments 

and twu full days of trial, the Ohio Elections Commission unanimously found that each of the 

above quoted statements were false and that there was clear and convincing evidence that David 

Krikorian had lied by making them in violation of R.C. 3517.21(1l)(10). That is, the Ohio 

Elections Commission unanimously found, by clear and convincing evidence, that David 

Krikorian falsely accused Jean Schmidt of directly or indirectly receiving money f rom the 

Turldsh government, either knowing that these statements were false, or with reckless disregard 

of their (rutil 01' falsity (which is the standard of New York Times v. Sullivan (1964), 376 U.S. 

254). 

David Krikorian's administrative appeals of these two Ohio Elections Commission cases 

to thc Franklin County Common Pleas Court (Schmidt v. Krikorian Franklin County C.P. Case 

Nos. 09CV -11-1 7707 and 09CV -11-17709) were subsequently dismissed, and David Krikorian 

chose to forgo any appeal of the February 25, 2010, Judgment Entry of the Franklin County 

Comt of Common Pleas dismissing his appeal from the Ohio Elections Commission's findings 

that he lied about Jean Schmidt. 

2. Krilmrian's Federal Court Action 

Instead, David Krikorian filed a federal lawsuit (Krikorian v. Ohio Elections Commission 

ef al. Southern Dist. Ohio Case No.1 :10-CV-I03) in which David Krikorian challenged the Ohio 

2 

DCB aCE - 0004 
49

ELections Commission's right to make findings against him for lying about Jean Schmidt. 

Originally, David Krikorian filed his federal1awsuit in the NOlthern District of Ohio under a 

different case number. But this transparent attempt to "forum shop" resulted in the Northern 

District promptly transfe11'ing the matter to the Southern District of Ohio. 

This federal court action was, in effect, an attempt to use the federal courts to void tile 

Ohio Elections Commission's findings that David Krikorian had Imowingly and recklessly lied 

about Jean Sclunidt. While David Krikorian did not name Jean Sclunidt as a pa1ty, we filed 

amicus curiae briefs on behalf of Jean Schmidt responding to the merits of David Krikorian's 

claims, and urging the court to dismiss Krikorian's lawsuit on Younger abstention grounds. 

On October 19, 2010, Judge Susan Dlott dismissed David Krikorian's federal lawsuit. 

3. Tbe Ohio Common Pleas Court Defamation Action 

In an ideal world, after the Ohio Elections Commission Complaints were filed, 01' at least 

after the Ohio Elections Commission found probable cause that David KJ'ikorian had lied, David 

Krikorian would have ceased his lies about Jean Schmidt receiving money from the Turkish 

government 01' its agents. Unfortunately. Jean Schmidt's hopes that the Ohio Elections 

Commission cases would deter David Krikorian from continuing his defamations of Jean 

Sclmlidt were dashed by David Krikorian's decision to repeatedly state that he "stand[s] by all of 

the statements that [he] made" about Jean Schmidt, that Jean Schmidt "is a paid puppet of the 

Turkish government involved in their denial campaie;n to suppress the truth about the Armenian 

genocide", that "Schmidt is bought and paid for by the Turkish lobby", that "the Turkish 

government is behind those contributions" and the like. Thus, on June 8, 2010, about a month 

before the statute of limitations would have expired 011 the earliest of Krikorian's republished 

statements, a defamation complaint was filed in State Court regarding these defamatory 

DCB aCE - 0005 
50

statements. Schmidt 11. Krikorian, Clermont County (Ohio) Common Pleas Court Case No. 

2010~CVC-1217 is a continuation of the two Ohio Elections Commission cases and the Federal 

case in that it also involves efforts by Jean Schmidt to obtain redress for David Krikorian's lies 

ahout her or efforts by David Krikorian to continue to publish those lies with impunity. 

4845..o362~2920, v. I 

DCB aCE - 0006 
51

EXHIBIT 6 

53

Clerk of the Hou~e of Representatives 

Legislative Re~ouree Center 

B-106 Cannon BUilding 

Wushlllgton. DC 20515 

Secretary of the Senate 

Office of Public Rccords 

232 Hart Building 

Washington. DC 20510 

----------- ------ LOBBYING REPORT 

Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page 

1. Regist.-ant Name :./j Urgdnl>:allon/Lobbpng Firm "J SdfEmploycd IndIVIdual 

George J lIochhrueckner & A~~OClate~. Inc 

2. Address I Check if different than p.-eviously .-epo.-ted 

Address 1 Private Road, Edgemere Park Address2 P.O. Box 637 

City Laurel State NY Zip Code 11948 Country USA 

3. Principal place of business (if different than line 2) 

City State Zip Code Country 

4a. Contact Name b. Telephone Number c. E-mail 5. Senate JDIt . In!('rna!ionalr\umb('r 

Mr George lIochbrueckner (631) 298-_ 18375-1003542 

7. Client Name L Self ~ Check if c1iellt is a state or local governmellf or instrllmellfali~~' 6. Iiouse JD# 

Turkish COdl,llonofAmerh.;a 322940037 

TYPE OF REPORT 8. Yea' 2008 Ql(1/l-3131)~ Q2(4!1-6/30)n Q3 (711-9130) Q4 (1011-12/31)?J 

9. Check if this filing amends a previously filed version of this report 

10. Check if this is a Termination Report G!J Termination Date 12!3li2008 I I. No Lobbying Issue Activity l~j 

INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 

12_ Lobbying 13. Organizations 

INCOME relating to lobbying activities for this reporting period EXPENSE relating to lobbying activities for this reporting period 

was: 

Less than $5000 

.;;- S 10,000.00 

Provide a good faith estimate, rounded to the nearest $] 0,000_ 

of all lobbying related income from the client (including all 

payments to the registrant by any other entity for lobbying 

activities 011 behalf of the client). 

Signature 

Printed ~ame and Title George J. Iloehbrueckner, President 

\6.0.1(' 

Less than $5 000 

14. REPORTING Check box to indicate expense 

accounting method. See instructions for description of options. 

.J Method A, 

:--J Method B_ 

Reportll1g amounts uSing I.[)A def1ll1tlons only 

Reporting amounts under sectIOn 6033(b)(S) of the 

Internal Revenue Code 

:\lethod C. Reporting amounts under ~eCl1on 1 ri2(e) of the intern<ll 

Revenue Code 

Date 01/15/2009 

Page i of2 
54

Rcg;5n~nr George J !lQchbruec)..nn & Assoclatcs. Inc Ci!elll :--:amc Tur~,~h COalll10n of :\mcnca 

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant 

engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide 

information as requested. Add additional page(s) as needed. 

15. General issue area code _________ : (one per page) 

16. Specific lobbying issues 

! Turkish-American issues. 

17. House(s) of Congress and Federal agencies Check if None 

~J S HOl Sl· OF REPRESE:-.' [A I [\ t.s. l. s. SEi\,\TE 

18. Name of each individual who acted as a lobbyist in this issue area 

1·lr~l Name 

iGeorge 

Last Name 

--~l~ochb-;:-ueckner 

Ii 

" 

Ii 

II 

J: 

I, Covcrcd O_~flcwl POSition (Ifapp!icab~) 

JlU.S. Congressman 1987-1994 

Suffix 

]'Ii' " I' 

19. Interest of each foreign entity in the specific issues listed on line 16 above '£ Check ifl\one ----

Printed Name and Title George J. Hochbrueckner. President 

,"6.0.1<: 

Nc\\ 

,c 

• I 

I 

J 

, J 

Page 2 of 2 
55

EXHIBIT 7 

57

Fcbnlary 14, 20:1 1 

Oma.t S. AflhInawy 

StaffDll'oG1:oJ' and Chief COUllsel 

Offie8 of Congl'Bssiollnl Ethies 

426 3n ' St.l'f)et, SW, Suit" 1110 

Wnshington, D.C. 20024 

Ro: ltEQUEST FOR INFORMATION 

Dear IvTl', Ashmawy: 

My l'fH5pOnSe to ymll' January 27, 2.011 Request for InfonnBtion in t.he t1me 

frame 200S··present is atO follows: 

TALDF has provid"d legal services to Reprcsentative Jean Schmidt 

eoncC'rning a Complaint she filed with t he Ohio J1:aeet,10l1G COllnniBBlon llnder 

Ohio law (1l1eging intentional misstatemonts of j"cL to affect the outcome of 

her congl'o:.-1sional race in 20GR by opponent David Krikonan, The CB;Sf! was 

adjudicated over two days of hearings in 20GB in. favor of' Schmidt on throe 

counts of illtentiol1£ll false statementH, 

2. TALDF provided Jegal services to Schmidt in tho appeal of the OEC';) 

decision" to the Ohio Court of Common Pleas, whi.dl concluded in her favor. 

3. TALDF legal services to Schrnjdt us amiens curiae in opposing' 

David suit against thl:~ Ohiu 1!~leet.Jorw Cmnmlssion in 2010 jn the 

United Stato.'] District Courts for the NOl'the.t'!1 and Southern Districts of 

Ohio challenging the constitutionalit.y of the OEC and its three rulings 

against Krikorian, The U.s' Dietl'iet Court fl)l' the Soulh"nl Distrid oi' Ohio 

ultimately tlismissnd the ,suit. 

4. TALDF has provided legfll service8 t.o Schmidt in hel' pending def;lmation 

suit against David Kl'ikorian and the Krikorian fol' Congfe::;s COH1D1itte{-; in 

the Ohio Court of Connnon Pleasj Clermont COl1Dty, V~rrjous molionn rcrnain 

out.8tanding. 

o. The costs of TALDyls logal services. enulnerated alx)"ve and provided by m.E', 

flr() attached as Exhibit L 

Pleaee alert me if you Hued anything furlher. 

TALDF 0001 

11-6574_0030 
58

Sincerely, 

BRUCE FEIN 

Senior Counsel 

TALDF 

TALDF 0002 

11-6574_0031 
59

EXHIBIT 8 

61

INVOICE 

January 29, 2008 

Lincoln McCurdy 

Re: Legal Services 

-

r 

January 7: 8 hrs. 

Cost per hr: $400.00 

TURKISH AMERICAN LEGAL DEFENSE FUND 

1025 CONNECTICUT AVE., N.W. 

WASHINGTON, D.C. 20036 

Please make payable to Bruce Fein & Associates, Inc. 

TALDF 0004 

11-6574_0033 
62

TURKISH AMERICAN LEGAL DEFENSE FUND 

February 25, 2009 

INVOICE 

Lincoln McCurdy 

Turkish Coalition of America 

RE: Legal Services 

Feb. 9· 

8hrs. 

Feb. 13 

hrs. 

Feb. 19-

Cost oer hr: 5400.00 

Please make check payable to Bruce Fein & Associates, Inc. 

Many thanks. 

Bruce 

-8 

TALDF 0005 

11-6574_0034 
63

TURKISH AMERICAN LEGAL DEFENSE FUND 

INVOICE 

Lincoln McCurdy 

RE: Legal Services (March 2009) 

March 9 

8 hrs. 

March 13- -6 hrs. 

March 19-

Cost per hour-$400.00 

Please make check payable to Bruce Fein & Associates, Inc. 

Many thanks. 

Bruce 

'-4 hrs. 

TALDF 0006 

11-6574_0035 
64

TURKISH AMERICAN LEGAL DEFENSE FUND 

INVOICE 

Lincoln McCurdy 

RE: Legal Services (April 2009) 

April 4: 8 hrs. 

April 10: 3 hrs. 

Cost her hour: $400.00 

TALDF 0007 

11-6574_0036 
65

Turkish American Legal Defense Fund 

INVOICE 

Lincoln McCurdy 

RE: Legal Services (April 28-May 2009) 

May 6: 1 hr. 

May 13-12 hrs, I 

May 14: 12 hrs. 

May 15: 8 hrs. 

May 18: 3 hrs. 

May 27: 4 hrs. 

Cost per hour: $400.00 

Please make check out to Bruce Fein & Associates, Inc. 

Many thanks. 

Bruce 

TALDF 0008 

11-6574_0037 
66

TURKISH AMERICAN LEGAL DEFENSE FUND 

INVOICE 

Lincoln McCurdy 

Re: Legal services (June 2009) 

1. June 4-5-10 hr' 

3. June 15-4 hrs. 

5. June 17-2 hrs. 

11. June 29-8 hrs. i 

Cost per hour-$400.00 

Please make check payable to Bruce Fein & Associates, Inc. 

Many thanks. 

Bruce 

J. 

TALDF 0009 

11-6574_0038 
67

Lincoln McCurdy 

RE: Legal Services-July 2009 

July 1-12 hrs 

July 9-8 hrs. 

July 10-8 hrs. 

July 17-8 hl_ 

July 27-4 hrs .. 

Cost per hour: $400.00 

Turkish American Legal Defense Fund 

Please make check payable to Bruce Fein & Associates, Inc. 

TALDF 0010 

11-6574_0039 
68

TURKISH AMERICAN LEGAL DEFENSE FUND 

INVOICE 

Lincoln McCurdy 

RE: Legal Services (August 2009) 

August 6-4 hrs. 

August 7-4 hrs. 

August 8-8 hrs. 

August 10-4 hrs. 

August 12-4 hrs. 

August 14-8 hrs. 

August 21-5 hrs 

August 22-8 hrs. 

August 23-8 h rs. 

August 24-8 hrs. 

August 28-8 hrs. 

August 30-4 hrs. 

August 31-8 h rs. 

Cost per hour: $400.00 

Please make check payable to Bruce Fein & Associates, Inc. 

Many thanks. 

Bruce 

TALDF 0011 

11-6574_0040 
69

TURKISH AMERICAN LEGAL DEFENSE FUND 

INVOICE 

Lincoln McCurdy 

RE: Legal Services (Sept. 2009) 

Sept.1-8 hrs .. 

Sept. 2-8 hrs 

Sept. 3-8 hrs 

Sept. 24-8 hrs. 

Sept. 26-8 hrs. 

Sept. 28-8 hrs. 

Sept. 29-8 hrs. 

Sept. 30-8 hrs. 

Cost per hour-$400 

Please make check payable to Bruce Fein & Associates, Inc. 

Many thanks. 

Bruce 

TALDF 0012 

11-6574_0041 
70

INVOICE 

Lincoln McCurdy 

TURKISH AMERICAN LEGAL DEFENSE FUND 

1025 CONNECTICUT AVENUE, N.W., SUITE 1000 

WASHINGTON, D.C. 20036 

Turkish Coalition of America 

RE: Legal Services (October 2009) 

Oct. 1 

Cost per hour: $400.00 

Please make check out to Bruce Fein & Associates, Inc. 

Many thanks. 

Bruce 

12hrs. 

TALDF 0013 

11-6574_0042 
71

INVOICE 

Lincoln McCurdy 

RE: Legal Services 

November 29-4 hrs. 

November 30-2 hrs. 

December 9-8 hrs. 

December 10-4 hrs .. 

r 

I 

Decem ber 19-8hrs. 

December 20-8 hrs 

TURKISH AMERICAN LEGAL DEFENSE FUND 

"7 

TALDF 0014 

11-6574_0043 
72

December 22-6 hrs. 

Cost per hour: $400.00 

TALDF 0015 

11-6574_0044 
73

TURKISH AMERICAN LEGAL DEFENSE FUND 

INVOICE 

Lincoln McCurdy 

RE: Legal Services (January 2010) 

January 18 ' 

I 

~ 

8 hrs. 

..... 

------------------------~1 

L------------------------------ Tanuary 21-

\ 

January 23-: 

January 24-

hrs. 

January 26-

January 28-

January 29-

8 hrs. 

Cost per hour: $400.00 

.. 

8 hrs. 

Please make check (0 Bruce Fein & Associates, Inc. 

8 hrs . 

:-6 hrs. 

2 hrs. 

J 

.. 

b 

TALDF 0016 

11-6574_0045 
74

TU=SH AMOOCANLLG~ DEL~~ ~ \ 

"" r"""s,,"~,(L,b.20rO) '" '\ ", ') 

INVOICE 

Lincoln McCurdy 

February 1: 

-4 hrs. 

February 3: 

Ius. 

February 9: 

-4 hrs. 

February 10: 

-6 hrs. 

February II: 

February 16: 

February 16: 1 

-4hrs. 

8 hrs. 

15 minutes. 

·20 minutes. 

·2 

__ I 

TALDF 0017 

11-6574_0046 
75

February 17: 

minutes. 

February 17: 

minutes. 

February 18: 

Feb. 18: 

February 18: 

February 19: 

10 hrs. 

February 20: 

February 21: 

February 21: 

minutes 

r'" -February 25: 

s 

February 26: 

30 minutes_ 

_ 15 minutes. 

4hrs. 

20 minutes. 

... .::J 

-1 hr. 

20 minutes. 

25 

--20 

t 

:-8 hrs. 

-90 

.u 

TALDF 0018 

11-6574_0047 
76

Cost per hour: $4{)O.OO 

~-- l... • J ." III 

C; : > 

~ 

TALDF 0019 

11-6574_0048 
77

4. March 1: 

6. March 2: 

4 hrs. 

7. March 3: 

, 

• 

~---.-

TURKISH AMERICAN LEGAL DEFENSE FUND 

BILLING STATEMENT: FEB-MARCH 2010 

:r 

1.25 hrs. 

,J 

} 

...... ~--. ----I, 

F 

J .... 

• 

7 hrs. 

, 

------

-" 

; 

TALDF 0020 

11-6574_0049 
78

Cost per hour: $400.00 

TALDF 0021 

11-6574_0050 
79

Turkish American Legal Defense Fund Billing Statement 

April 2010 

------"- r __ --

, 5. April 16: 

2 hrs. 

7. April 19: , 

4 hrs. 

8. April 20: 

10. April 22: 

11. April 23: 

hrs. 

12. April 26: 

4h,," 

-4 hrs. 

• 

-' 

4 

----"-

14. April 28: 

8 hrs. 

Cost her hour: $400.00 

'f 

TALDF 0022 

11-6574_0051 
80

TURKISH AMERICAN LEGAL DEFENSE FUND BRUCE FEIN BILLING STATEMENT 

MAY 2010 

1. May 4, 2010: 

2. May 5, 20l0_: ____ ~_ 

, 

4. May 10, 2010: 

5. May 12, 2010: 

6. May 13, 2010: 

·Shrs. 

7. May 14, 2010: 

-8hrs. 

8. May 19, 2010: 

( 

10. May 24, 2010: 

4 hrs. 

11. May 26, 2010: 

hrs. 

12. May 28, 2010: 

Cost per hour: $400.00 

·6 hrs. 

2 hrs. 

·8 hrs. 

4 hrs. 

8 hrs. 

B hrs. 

·6 

TALDF 0023 

11-6574_0052 
81

Turkish American Legal Defense Fund 

Bruce Fein's July, 2010 Billing Statement 

July7: ' 

1 hr. 

l-- l 

F 

! r'- & l.... 

r===-____ ~ 

r 

.,. 

Cost per hour: $400.00 

Please make check to: t>ruce Fein & Associates, Inc. 

2& 

.. 

\ 

1.,.,-----

.. 

, 

= 

'-~ 

., 

TALDF 0024 

11-6574_0053 
82

, 

Sept. 20; 

Sept. 26; 

Sept. 27: 

Sept. 29; 

TURKISH AMERICAN LEGAL DEFENSE FUND 

BRUCE FEIN BILLING STATEMENT SEPTEMBER 2010 

--.s hrs. 

4 hrs. 

j 

Cost per hour: $400.00 

·8 hrs. 

6 hrs. 

m 

,-

I 

TALDF 0025 

11-6574_0054 
83

'-

TURKISH AMERICAN LEGAL DEFENSE FUND 

BRUCE FEIN'S BILLING STATEMENT FOR OCTOBER 2010 

L r-'-

3. October 11: 

-8 hrs. 

4. October 12: : 

-8 hrs. 

5. October 19: 

·6 hrs. 

6. October 20: . 

6 hrs. 

c 

.~----~ 

I 10. October 27: . 1 hr. 

11. October 28: 

8 hrs. 

Cost per hour: $400.00 

LiW!! rl 

1 

TALDF 0026 

11-6574_0055 
84

Bruce Fein's Billing Statement for the Turkish American Legal Defense Fund 

November 2010 

November 1: 

November 2: . 

fI 

November 15: 

November 16: 

November 18: 

Cost per hour: $400.00 

-8 hrs. 

..,._$t hr<;. 

r 

'-5 hrs. 

-8 hrs. 

1 hr. 

J 

H:~ hrs. 

TALDF 0027 

11-6574_o056 
85

Bruce Fein's Turkish American Legal Defense Fund Billing Statement 

December 2010 

t 

,----

December 14: ' 

2 hrs. 

I 

J 

- - [ -- Cost per hour: $400.00 

TALDF 0028 

11-6574_0057 

87

EXHIBIT 9 

89

SALTZMAN & EVINCH, P.C. 

METROPOLlTAN SQUARE 

655 FlFTEE"l1l SIRn". NW 

F STREIT LOllBY. SUITE 225 

WASHINGTON. DC 20005-5701 

TELEPHONE (202) 637.-

FACSIMILE (202) 637-9876 

ATTORNEYS AT LAW 

l'd)ruary 17, zcn 1 

''vlr. Omar Ashl11<1wv, Staff Director and Chid Counsel 

Ofiice of Congressi,;nal Ethks 

United States House of Representatives 

4253,·1 Street, 5W 

Suite 1110 

Washington, DC 20024 

PD. Box 895 

Washington, DC 20515-0R95 

Re: Request for Information; Legal Services to RQj2. lean Schmidt 

Dear Mr. Ashmawy: 

DA"1D S. SALTZMr\l'\! 

GONAY EViNG! (6VUNQ) 

\vww.TURKLAw.NET 

Enclosed please find all. infonnat"ion in 111y pl..)ssestlion relevant to your request 

for information of January 27, 2011. 

J spoke on Januarv 28,20]] with investigative Counsel Kedric Payne, who stated 

that your {:;tnce is interested in eviden(:e of what my firm 0t r WiJf-, paid fur legal services 

on Rep. Schmidt's behalf. Thus, we have redacted from the invoices produced 

descriptions ot the lVork performed. i\S the invoices also include information 

pertaining to numerouo matters unrelated to Rep. Schmidt, such inlormation has also 

been redacted. The invoices tally 87.3 hours of kg.,! servires on Rep. Schmidt's behalf, 

billed al an hourly rate of $325. Please unders\,md thull have done additional, thougb 

not substantial, work on Rep. Schmidt's matters but have not yet submitted invoices for 

payment. 

j Ivill also subnl1t this infoflTwtion via ek>ctronk mail in a pdf file to iv1r. P~yl1ef 

as he and.l discussed by telephone earlier loday. 

Plea':ic advise m!.1 if 1 can be of further assistance to your office. 

8all_001 

11-6574_0059 
90

Brief Description Of Legal Matters on Behalf of Rep. Jean Schmidt 

Since 2008, David Saltzman and his law finn have provided legal services on behalf of 

Jean Schmidt in her actions before: (I) the Ohio Elections Commission (and administrative 

appeals from the OEC); (2) federal court; and, (3) Ohio Common Pleas Court. All of these 

related to Jean Schmidt's efforts to protect and preserve her reputation against falsehoods 

disseminated by David Krikorian, twice a congressional candidate in Ohio's second district. 

1. The Ohio Elections Commission False Statement Cases. 

Two days before the November 4, 2008, general election (at which Jean Schmidt was 

standing for reelection to Congress), David Krikorian disseminated fliers - including at the 

parking lots of the church where Jean Schmidt worshipped - in which Krikorian stated that Jean 

Schmidt was "taking money from a foreign government [Turkey] that is killing our soldiers", 

that "Jean Schmidt has taken $30,000 in blood money from Turkish government sponsored 

political action committees to deny the slaughter of 1.5 million Annenian men, women and 

children by the Ottoman Government during World War II", and that "This infonnation is public 

record and can be found on the Federal Elections Commission data base" [as this statement 

purports to reference facts that support the statements that Turkish government sponsored 

political action committees donated $30,000]. 

Rep. Jean Schmidt filed two Complaints before the Ohio Elections Commission 

regarding these statements, pursuant to Ohio Revised Code Section 3517.21(B)(10), which 

makes it a violation to "[p]ost, publish, circulate, distribute, or otherwise disseminate a false 

statement concerning a candidate, either knowing the same to be false or with reckless disregard 

of whether it was false or not, if the statement is designed to promote the election, nomination, or 

defeat of the candidate". The Complaint in OEC Case No. 2009E-003 was filed on April 29, 

8all_003 

11-6574_0060 
91

2009. The Complaint in OEC Case No. 2009E-012 was filed on July 21, 2009. The two cases 

were consolidated and tried together. 

The two consolidated Ohio Elections Commission cases were hard fough!. David 

Krikorian was represented by experienced Ohio election and first amendment lawyers, as well as 

by prominent lawyers based in Los Angeles and Washington, D.C. After months of discovery 

(including depositions in Ohio, Washington D.C. and Kentucky), motions, procedural arguments 

and two full days of trial, the Ohio Elections Commission unanimously found that each of the 

above quoted statements regarding Rep. Schmidt were false and that there was clear and 

convincing evidence that David Krikorian had lied by making them in violation of RC. 

3517.21(B)(IO). That is, the Ohio Elections Commission unanimously found, by clear and 

convincing evidence, that David Krikorian falsely accused Rep. Jean Schmidt of directly or 

indirectly receiving money from the Turkish government, either knowing that these statements 

were false, or with reckless disregard of their truth or falsity (which is also the standard for 

public figure defamation in New York Times v. Sullivan, 376 U.S. 254 (1964)). 

David Krikorian's administrative appeals of these two Ohio Elections Commission cases 

to the Franklin County Common Pleas Court (Schmidt v. Krikorian, Franklin County c.P. Case 

Nos. 09CV -11-17707 and 09CV -11-17709) were subsequently dismissed, and David Krikorian 

chose to forgo any appeal of the February 25, 2010, Judgment Entry of the Franklin County 

Court of Common Pleas dismissing his appeal from the Ohio Elections Commission's findings 

that he lied about Jean Schmidt. 

2. Krikorian's Federal Court Action 

Instead, David Krikorian filed a federal lawsuit (Krikorian v. Ohio Elections Commission 

et al. Southern Dis!. Ohio Case No. I: IO-CV -103) in which he challenged the Ohio Elections 

Salt_004 

11-6574_0061 
92

Commission's right to make fmdings against him for lying about Rep. Jean Schmidt. Originally, 

David Krikorian filed his federal lawsuit in the Northern District of Ohio under a different case 

number. But this transparent attempt to "forum shop" resulted in the Northern District promptly 

transferring the matter to the Southern District of Ohio. 

This federal court action was, in effect, an attempt to use the federal courts to void the 

Ohio Elections Commission's findings that David Krikorian had knowingly and recklessly made 

false statements about Rep. Jean Schmidt. Whilc David Krikorian did not name Rep. Schmidt as 

a party, we filed amicus curiae briefs on he behalf responding to the merits of David Krikorian's 

claims, and urging the court to dismiss Krikorian's lawsuit on Younger abstention grounds 

(Younger v. Harris, 401 U.S. 37 (1971 ». 

On October 19, 2010, U.S. District Judge Susan Dlott dismissed David Krikorian's 

federal lawsuit. 

3. The Ohio Common Pleas Conrt Defamation Action 

In an ideal world, after the Ohio Elections Commission Complaints were filed, or at least 

after the Ohio Elections Commission found probable cause that David Krikorian had lied, David 

Krikorian would have ceased his lies about Rep. Jean Schmidt receiving money from the Turkish 

government or its alleged agents. Unfortunately, Jean Schmidt's hopes that the Ohio Elections 

Commission ruling and written reprimands would deter David Krikorian from continuing his 

defamations were dashed by David Krikorian's decision to repeatedly state that he "stand[s] by 

all of the statements that [he] made" Rep. Schmidt, that she "is a paid puppet of the Turkish 

government involved in their denial campaign to suppress the truth about the Armenian 

genocide", that "Schmidt is bought and paid for by the Turkish lobby", that "the Turkish 

government is behind those contributions" and the like. Thus, on June 8, 2010, about a month 

Salt_ODS 

11-6574_0062 
93

before the statute of limitations would have expired on the earliest of Krikorian's republished 

statements, Rep. Schmidt filed a defamation complaint in State Court regarding these statements. 

Schmidt v. Krikorian, Clermont County (Ohio) Common Pleas Court Case No. 20lO-CVC-12l7 

is a continuation of the two Ohio Elections Commission cases and the Federal case in that it also 

involves efforts by Jean Schmidt to obtain redress for David Krikorian's lies about her or efforts 

by David Krikorian to continue to publish those lies with impunity. 

Salt_006 

11-6574_0063 

95

EXHIBIT 10 

97

m~~TA LEGAL DEFENSE FUND 

To: Mr. G. Lincoln McCurdy 

Turkish Coalition of America, Inc. 

Re: TALDF Fees for September 1 - December 15, 2008 

INVOICE 

David S. Saltzman 

Saltzman & Evincb, PC 

U.S. Soc. Sec. No._ 

DC Bac No. 436201 

Firm's Employ"er Identification No_ 

Time: • hrs. @ S32SIhr. ~ $_ (Atty. David Saltzman) 

Expenses: •••••••••• 

AMOUNT DUE THIS INVOICE: 

Please remH via maillo the Saltzman & Evinch PC at 655 15th St., N.W., Suite 225-F, 

Washington, DC 20005, or via telegraphic transfer as follows: 

David S. Saltzman 

Salt_DD7 

11-6574_0065 
98

mm~TA LEGAL DEFENSE FUND 

To: Mr. O. Lincoln McCurdy 

Turkish Coalition of America, Inc. 

Re: TALDF April I, 2009-June 30, 2009 

INVOICE 

David S. Saltzman 

Saltzman & Evinch, PC 

u.s. Soc. Sec. No._ 

DC Bar No. 436201 

Finn's Employer Idenlification No._ 

Time: • brs. @ S3251hr. = ~ (Atty. David Saltzman) 

Expenses: ••••••••••••• ($5.00). 

AMOUNT DUE THIS INVOICE: USS_ 

Please remit via mail to the Saltzman & Evinch PC at 655 15th St., N.W., Suite 225~F) 

Washington, DC 20005, or via telegraphic transfer as follows: 

.~ '-- , -- " 

David S. Saltzman 

Salt_008 

11-6574_0066 
99

~~TA LEGAL DEFENSE FUND 

To: Mr. G. Lincoln McCurdy 

Turkish Coalition of America, Inc. 

Re: TALDF July. 1,2009 - Sept. 30, 2009 

INVOICE 

David S. Saltzman 

Saltzman & Evinch, PC 

u.s. Soc. Sec. No._ 

DC Bar No. 436201 

Firm's Employer Identification No._ 

Time: • hrs. @ $325/hr. ~ ~ (Atty. David Saltzman) 

AMOUro;T DUE THIS INVOICE: uss_ 

Please remit via mail to the Saltzman & Evinch PC at 655 15th St., N.W., Suite 22S-F. 

Washington, DC 20005, or via telegraphic transfer as follows: 

David S. Saltzman 

Salt_009 

11-6574_0067 
100

~~~TA LEGAL DEFENSE FUND 

To: Mr. G. Lincoln McCurdy 

Turkish Coalition of America, Inc. 

Re: T ALDF Oct. 1, 2009 - Dec. 31, 2009 

INVOICE 

David S. Saltzman 

Saltzman & Evlncb, PC 

u.s. Soc. Sec. No._ 

DC Bar No. 436201 

Firm's EmployeT Identification No._ 

Tim" • hrs. @$325Ihr. = $_ (Atty. David Saltzman) 

EXpenses: $69.1_~ •••••••••••••••••• 

AMOUI'iT DUE THIS INVOICE: uss_ 

Please remit via mail to the Saltzman & Evinch PC at 655 15th St., N.W., Suite 225-F. 

Washington, DC 20005, or via telegraphic transfer as follows: 

8all_010 

11-6574_0068 
101

David S. Saltzman 

Salt_011 

11-6574_0069 
102

WJ)~TA. LEGAL DEFENSE FUND 

To: Mr. G. Lincoln McCurdy 

Turkish Coalition of America, Inc. 

Re: TALDF Jan. 1, 2010-March 31, 2010 

INVOICE 

David S. Saltzman 

Saltzman & Evioch, PC 

u.s. Soc. Sec. No._ 

DC Bar No. 436201 

Firm's Employer Identification No._ 

Time: • hrs. @ $325Ihr. ~ _ (Atty. David Saltzman) 

Expenses: (none) 

AMOUNT DUE THIS INVOICE: USS_ 

Please remit via mail to the Saltzman & Evinch PC at 655 lSIh St., N.W., Suite 225-F, 

Washington, DC 20005, or via telegraphic transfer as follows: 

8alt_012 

11-6574_0070 
103

David S. Saltzman 

Salt_013 

11-6574_0071 
104

mM~TA LEGAL DEFENSE FUND 

To: Mr. G. Lincoln McCurdy 

Turkish Coalition of America, Inc. 

Re: TALDF April 1-June 30, 2010 

INVOICE 

David S. Saltzman 

Saltzman & Evinch, PC 

u.s. Soc. Sec. No._ 

DC Bar No. 436201 

Firm's Employer Identification No._ 

n1DD I rmmn 

I 

Time: • hrs. @ S3251hr. ~ ~ (Atty. David Saltzman) 

Expenses: (none) 

AMOUNT DUE THIS INVOICE; USS_ 

Please remit via mail to the Saltzman & Evinch PC at 655 15" St., N.W., Suite 22S-F, 

Washington, DC 20005, or via telegraphic transfer as follows: 

~-----

David S. Saltzman 

8all_014 

11-6574_0072 
105

EXHIBIT 11 

107

Inquiry: General" Ledger History Client '13292· TURKISH AMERICAN LEGAL DEFENSe 

M a tt er: 24 S h c ml 'dt v. K r Ik orlan User: DWR 

Type Bill Dale Cash 1 PPD Fees Expenses SurchgfTaxllnt AIR Balance 

1 Bill 112858 01/15/200 0.00 915.00 0.00 0.00 915.00 

2 Bill 114023 02113/200 0.00 0.00 0.00 0.00 915.00 

3 

~~~ ~~~¥a ~~200 91~ 65.00 0.00: 0.00 960.00 

4 04/13/200 916.00 -~OO 0.00 65.00 

5 Cash 114189 04/13/200 65,00 65.00 0.00 0.00 0.00 

6 Bill 114895 04/13/200 0.00 1,170.00 0.00 13.73 1,183.73 

7 Bill 115628 05/15/2009 0.00 1,852.50 38.34 0.00 3,074.57 

B Bill 117002061151200 0.00 5,720.00 

~:~ 1~.?5 B,B16.62 

9 Cash 11489507/06/2009 1,170.00 1,170.00 0.00 7,646.62 

10 Cash 11562807/06/200 1,890.84 1,852.50 38.34 0.00 5,755.78 

" Cash 11700207/06/200 13.73 9.23 4.50 0.00 5,742.05 

12 Bill 117109071151200 0.00 5,070.00 106.52 0.00 10,916.57 

13 Bill 117933081141200 

~~:~~ 20,8'35.50 3,431.99 85.66 35,271.72 c-:",' Cash 117002!Sl8/17/iw 5,7'0.77 O.()O O',~O 29,560.95 

~ Cash 117109fo8/17/200 ~~.81 1,669.29 106.52 0.00 27,785.14 

16 Cash 1179331081171260' 3,431.99 -O~OO 3,431.99 0.00 24,353.15 

17 Bill 1185731091101200 0.00 36,867,00 1,345.01 51.01 62,616.17 

18 Bill 118254 10/15J200 0.00 --30;132-:-50 4,038.59 363.54 97,150.BO 

19 Silt 120356 11113/2009 0.00 5,315.50 5,38B.81 936.72 10B,791.83 

20 Bill 120855 12/11/2009 0.00 910.00 1,199.89 1,449,29 ~.01 

21 Cash 114895 01/11/2010 13.73 0.00 '0:'00 --'-3.73 112,337.28 

22 Cash 117002 01/11/2010 17.55 0.00 0.00 17,55 112,319.73 

23 Cash 117109 01/11/2010 3,400.71 3,400.71 0.00 0.00 108,919.02 

24' Cash 117933 01/11/2010 20,921.16 20,835.50 0.00 

25 Cash 118573 01/11/2010 38,263.02 36,867.00 1,345.01 .-----m1 f--~ 49,734.84 

28 Cash 119254,0111112010 34,534.63 30,132.50 4,038.59 363.54 15,200.21 

27 Cash 120356·01/11/2010 11,641.03 5,315.50 5,388.81 936.72 3,559.18 

28 Cash 120855 01111/201 3,559.18 910,00 1,199.89 1,449.29 0.00 

29 Bill 121316 01115/201 0.00 1,202.50 1.26 0.00 1,203.76 

30 BUI 121986 02/121201 0.00 10,164.50 291.64. 0.00 

·1~ ~}- ~- 122678 03/12/201 0.00 9,535.50 310.88 18.06 21,524.34 

12-1'316 03124/2010 1,203.76 1,202.50 1.26; 0.00 20,320.58 

T3 ~ ---:ri1986 04/13/201 10,456.14 10,164.50 291.64 0.00 9,864.44 

34 Cash 122678 04/13/201 9,864.44 9,535.50 310.88 18.06 0.00 

35 8111 123392 04119/201 0.00 2,632.50 122.12 0.00 2,754.62 

36 8m 124114 05/14/201 0.00 1,173.50 20.70 0.00 3,948.82 

~ ~.-- - 123392 06/07/201 2,754.62 2,632.50 122.12 0.00 1,194.20 

38 124~1/201 , 0.00 2,600.00 51.27 41.32 3,686.79 

39 Cash 124114.06/281201Oj 1,194.20 1,173.50 20.70 0.00 2,692.59 .. 

40 Bill 12560807/15/2010: 0.00 2.405.00 495.74 0.00 5,593.33 

41 Cash 124974 08/04/2010 2,651.27 2,600.00 51.27 0.00 2,942.06 

42 Casn 125608 08/04/2010 249.47 0.00 249.47 0.00 2,692.59 

43 Cash 125608 08/04/201 2,651.27 2,405.00 246.27 ~~o 41.32 

44 Adj 124974 08/11/201 0.00 000 0.00 ~:2 0.00 

45 Bill 126852 08/13/201 0.00 877.50 --4-.96 0.00 882.46 

46 Bill 127133 09/13/2010 0.00 130.00 49.44 0.00 1,061.90 

47 I

Cash 126852 C9/301201 882.46 877.50 4.96 0,00 179.44 

48 Bill 128317 10/14/201 0.00 9,753.00 481.52 0.00 10,413.96 

:~- ~Sh 12713311110112010 179.44 130.00 49.44 0.00 10,234.52 

Cash 128317[111OT1201 10,234.52 9,753.00 481.52 0,00 0.00 

51 Bill 12872811/11/201 0.00 11,358.50 199.30 0.00 11,557.80 

52 eill 129453 121101201 0.00 18,68B.50 1,331.36 0.00 31,577.66 

53 Bill 13055401117/2011 0.00 4,830.00 90.52 473.66 36,971.84 

54 Cash 128728 02/02/2011 11,557.80 11,358.50 199.30 0.00 25,414.04 

Page: 1 

DCB aCE - 0008 
108

Inquiry: General- Ledger History Client: 13202 - TURKISH AMERICAN U::'GAL DEFENSE 

Matter 24 Schmldlv Krikorian ser. -DWR ~ -------

Comment 

1 From bill #112850 

2 From bill #11402.3 

3 Frombill#1141B9 -~- ._._- -~--.-~ 

4 TURKISH AMERICAN U::GALOEFENSE 

r+- TURKISH AMERICAN LEGAL DEFENSE 

6 From bill #114895 

7 From bill #115628 

~,s, From bill #117002 -

iwRklSH AMERICAN LEGAL DEFENSE - - 9 --~ --- 10 TURKISH AMERICAN LEGAL OEFEN"SE -~ 

11 TURKISH AMERICAN LEGAL DEFENSE -------- 12 From bill #117109 - - -

13 From bill #117933 

14 TURKISH AMERiCAN LEGAL DEFENSE ----- -- It- TURKISH AMERICAN LEGAL DEFENSE 

TURKISH AMERICAN LEGAL DEFENSE ----- - -- - -- ----~---~ --- -

~~ 17 From bJ11 #118573 

,. From bill #119254 

19 From bill #120356 

~o_ From bill #120655 - -- -- ~ 

21 TURKISH AMERICAN LEGAL DEFENS~----~- - -- - -

22 TURKISH AMERICAN LEGAL DEFENSE ----- ------ -----

23 TURKISH AMERICAN LEGAL DEFENSE I,. TURKISH AMERICAN LEGAL DEFENSE ---------~-------

25 TURKISH AMERICAN LEGAL DEFENSE 

26 TURKISH AMERICAN LEGAL DEFENSE ---- ------ 27 TURKISH AMERICAN LEGAL DEFENSE 

2. TURKISH AMERICAN LEGAL DEFENSE 

29 From bill #121316 

30 From bill #121986 

" From bill #122678 --

~f TURKISH AMERICAN LEGAL DEFENSE 

TURKISH AMERICAN LEGAL DEFENSE -- -- - -- - --- - 33 

34 TURKISH AMERICAN LEGAL DEFENSE 

35 From bill #123392 

36 Frombilf#124114 

37 TURKISH AMERICAN LEGAL DEFENSE - - -- --- ~-

~~ From bill #124974 -~- -- - -- 39 TURKISH AMERICAN LEGAL DEFENSE 

40 From bill #125608 

41 TURKISH AMERICAN LEGAL DEFENSE -

42 TURKisH AMERICAN LEGAL DEFENSE -- ~3_ TURKISH AMERICAN LEGAL DEFENSE 

W/O INTEREST ---------- --- ---- --- 44 -- --- -- ~ 

~--."" "- 45 From bill #126852 

46 From bill #127133 

47 TURKISH AMERICAN LEGAL DEFENSE 

4. From bill #128317 

~~ TURKISH AMERICAN LEGAL DEFENSE 

50 TURKISH AMERICAN LEGAL DEFE"NSE -- ~ 

51 From bill fl.128728 -- 52 From bill #129453 

r-#- 54 ~~:~~~~~CAN LEGAL DEFENSE 

Page: 2 

DCB DCE - 0009 
109

CHESTER WILLCOX & SAXBE L.L.P. 

Attorneys and Counselors at Law 

Telephone 614_ 65 East State Street Suite 1000, Columbus, Ohio 43215-4213 

January 15, 2009 

Fax 6141221-4012 

Billing 12/31/2008 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUR AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

invoice# 112858 DeB 

Our File 13292 00024 

$0.00 

(0.00) 

$0.00 

915.00 

$915.00 

$915.00 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

RETURN THIS PAGE WITH PAYMENT 
110

CHESTER WILLCOX & SAXBE L.L.P. 

Attorneys and Counselors at Law Telephone 614_ 65 Bast State Streot Suite 1000, Columbus, Ohio 43215-4213 F.E.!. No. 31-4422499 

January 15, 2009 

Billed through 1213112008 

Invoice Number 112858 

Our file# 13292 00024 

TURKISH AMERICAN LEGAL DEFENSE FUND 

c/o BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUR AVE" N.w" SUITE 1000 

WASHINGTON, DC 20036 REDACTED 

Schmidt v. Krikorian 

Balance forward as of invoice January 1, 1900 

Payments received since last invoice 

Past Due Balance (Disregard if Paid) 

SUMMARY OF BILLED AMOUNTS 

DCB BREY, DONALD C. 

TOTAL PROFESSIONAL SERVICES 

3.00 hrs 

~hrs 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

TOTAL BALANCE DUE ON ACCOUNT 

$0.00 

(0.00) 

$0.00 

305.00 thr __ ,;,$9,..,1.;5",.0".0 

$915.00 

915.00 

$915.00 

$915.00 

DCB aCE - 0011 
111

CHESTER WILLCOX & SAXBE L.L.P. 

Attorneys and Counselors at Law 

Telephone 614_ 65 East State Street Suite 1000) Columbus, Ohio 43215A213 

February 13, 2009 

Fax 614lnHOIZ 

Billing 01/31/2009 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUR AVE., N.w., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

Invoice# 114023 DeB 

Our File 13292 00024 

$915.00 

(0.00) 

$915.00 

$915.00 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

RETURN THIS PAGE WITH PAYMENT 

DCB aCE - OOl2 
112

CHESTER WILLCOX & SAXBE L.L.P. A ttorneys and Counselors at Law 

Te{(iphone 614_ 65 East State Street Suite 1000, Columbus) Ohio 43215-4213 F.E.I. No. 3H422499 

February 13, 2009 

Billed through 01/31/2009 

Invoice Number 114023 

Ourfile# 13292 00024 

TURKISH AMERICAN LEGAL DEFENSE FUND 

c/o BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICURAVE .• N.W., SUITE 1000 

WASHINGTON. DC 2UU36 

Schmidt v. Krikorian 

Balance forward as' of invoice January 15, 2009 

Payments received since last invoice 

Past Due Balance (Disregard if Paid) 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

EFFECTIVE JANUARY 1,2009. THE FIRM 

INCREASED THE PRICE OF PHOTOCOPIES 

FROM $.15 TO $.18. THIS PRICE CAPTURES 

ONLY OUR ACTUAL COST AND APPLIES TO 

BLACK AND WHITE AND COLOR COPIES. 

$915.00 

(0.00) 

$915.00 

$0.00 

$915.00 

$915.00 

DCB OCE - 0013 
113

CHESTER WILLCOX & SAXBE L.L.P. 

Attorneys and Counselors at Law 

Telephone 614_ 65 East State Street Suite 1000, Columhus, Ohio 43215~4213 

March 17,2009 

Fax614/221-4012 

Billing 02/28/2009 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUR AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

Invoice# 114189 DCB 

Our File 13292 00024 

$915.00 

(0.00) 

$915.00 

65.00 

$65.00 

$980.00 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

RETURN THIS PAGE WITH PAYMENT 

DCB DCE - 0014 
114

CHESTER WILLCOX & SAXBE L.L.P. 

Attorneys and Counselors at Law 

Telephone 614_ 65 East State Street Suite lOOO, Columbus, Ohio 43215~4213 

TURKISH AMERICAN LEGAL DEFENSE FUND 

c/o BRUCE FEIN 

March 17, 2009 

Billed through 

Invoice Number 

Ourfile# 

F.E.I. No. 31·4422499 

02/28/2009 

114189 

13292 00024 

RESIDENT SCHOLAR 

1025 CONNECTICUR AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 REDACTED 

Schmidt v. Krikorian 

Balance fOIWard as of invoice February 13, 2009 

Payments received since last invoice 

Past Due Balance (Disregard if Paid) 

SUMMARY OF BILLED AMOUNTS 

DCB BREY, DONALD C, 

TOTAL PROFESSIONAL SERVICES 

0.20 hrs 

-----0.20 hrs 

TOTAL 01" NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

$915.00 

(0.00) 

$915.00 

325.00 thr __ """$6""5,,,,.0,:,-0 

$65.00 

65.00 

$65,00 

$915.00 

$980.00 
115

CHESTER WILLCOX & SAXBE L.L.P. 

Attorneys and Counselors at Law 

Telephone 614_ 65 East State Street Suite 1000, Columbus, Ohio 43215~4213 

April 13. 2009 

Fax 614/221-401Z 

Billing 03/31/2009 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUR AVE.. N.w .. SUITE 1000 

WASHINGTON. DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Late Payment Charge 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

Invoice# 114895 DCB 

Our File 13292 00024 

$980.00 

(0.00) 

$980.00 

1.170.00 

13.73 

$1,183.73 

$2,163.73 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

RETURN THIS PAGE WITH PAYMENT 
116

CHESTER WILLCOX & SAXBE L.L.P. 

Attorneys and Counselors at Law 

Telephone 614_ 65 nast State Street St:ite 1000, Columbus, Ohio 43215~4213 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

April 13, 2009 

Billed through 

Invoice Number 

Ourfile# 

F.R.I. No. 31-4422499 

03/31/2009 

114895 

13292 00024 

RESIDENT SCHOLAR 

1025 CONNECTICUR AVE., N.w" SUITE 1000 

WASHINGTON. DC 20036 REDACTED 

Schmidt v. Krikorian 

Balance forward as of invoice March 17, 2009 

Payments received since last invoice 

Past Due Balance (Disregard if Paid) 

$980.00 

(0.00) 

$980.00 
117

13292 00024 Invoice# 114895 

SUMMARY OF BILLED AMOUNTS 

DCB BREY, DONALD C, 3,60 hrs 

~hrs 

TOTAL PROFESSIONAL SERVICES 

325,00 Ihr 

LATE PAYMENT CHARGE ON PAST DUE BALANCE 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

Page 2 

$1,170,00 

$1,170,00 

1,170,00 

13,73 

$1,183,73 

$980,00 

$2,163.73 

DCB aCE - 0018 
118

CHESTER WILLCOX & SAXBE L.L.P. 

Attorneys and Counselors at Law Telephone 614/_ 65 East State Street Suite 1000, Columbus, Ohio 43215·4213 

May 15, 2009 

Fax 6141221-4012 

Billing 04/30/2009 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUR AVE., N.W., SUITE 1000 

WASHINGTON. DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

Invoice# 115628 DeB 

Our File 13292 00024 

$1,183.73 

(0.00) 

$1,183.73 

1,852.50 

38.34 

$1,890.84 

$3,074.57 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

RETURN THIS PAGE WITH PAYMENT 
119

CHESTER WILLCOX & SAXBE L.L.P. 

Attorneys and Counselors at Law 

Telephone 614_ 65 East State Street Suite 1000, Columbus, Ohio 43215-4213 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

RESIDENT SCHOLAR 

May 15, 2009 

Billed through 

Invoice Number 

Ourfile# 

F.E.!. No. 31-4422499 

0413012009 

115628 

13292 00024 

1025 CONNECTICUR AVE" N,W., SUITE 1000 

WASHINGTON, DC 20036 REDACTED 

Schmidt v. Krikorian 

EXPENSES 

Balance forward as of invoice April 13, 2009 

Payments received since last invoice 

Past Due Balance (Disregard if Paid) 

04/30/2009 PHOTOCOPY SERVICE @ $.18 

TOTAL DISBURSEMENTS 

$1,183.73 

(0,00) 

$1,183.73 

38.34 

$38.34 

DCB DCE - 0020 
120

13292 00024 Invoice# 115628 

SUMMARY OF BILLED AMOUNTS 

DCB BREY, DONALD C. 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

5.70 hrs 

-----s:ro hrs 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

325.00 thr 

Page 2 

$1,852.50 

$1,852.50 

1,852.50 

38.34 

$1,890.84 

$1,183.73 

$3,074.57 

DCB OCE - 0021 
121

CHESTER WILLCOX & SAXBE L.L.P. 

Attorneys and Counselors at Law 

Telephone 614_ 6S East State Street Suite 1000, Columbus, Ohio 43215A213 

June 15. 2009 

Fax 614/221-4012 

Billing 05131/2009 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICURAVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

Late Payment Charge 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

Invoice# 117002 DCB 

Our File 13292 00024 

$3,074.57 

(0.00) 

$3,074.57 

5,720.00 

4.50 

17.55 

$5,742.05 

$8,816.62 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

RETURN THIS PAGE WITH PAYMENT 

DCB aCE - 0022 
122

CHESTER WILLCOX & SAXBE L.L.P. 

Attorneys and Counselors at Law 

Telephone 614_ 65 East State Street Suite 1000, Columbus, Ohio 43215-4213 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

RESIDENT SCHOLAR 

June 15, 2009 

Billed through 

Invoice Number 

Ourflle# 

1025 CONNECTICUR AVE" N,W" SUITE 1000 

WASHINGTON. DC 20036 REDACTED 

Schmidt v. Krikorian 

Balance forward as of invoice May 15, 2009 

Payments received since last invoice 

Past Due Balance (Disregard if Paid) 

F.E.]. No. 31-4422499 

05/31/2009 

117002 

13292 00024 

$3,074.57 

(0.00) 

$3,074.57 

DCB aCE - 0023 
123

13292 00024 Invoice# 117002 

REDACTED 

EXPENSES 

0513112009 PHOTOCOPY SERVICE@ $.18 

TOTAL DISBURSEMENTS 

SUMMARY OF BILLED AMOUNTS 

DCB BREY, DONALD C. 17.60 hrs 

17:60 hrs 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

325.00 Ihr 

. LATE PAYMENT CHARGE ON PAST DUE BALANCE 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

Page 2 

4.50 

$4.50 

$5,720.00 

$5,720.00 

5,720.00 

4.50 

17.55 

$5,742.05 

$3,074.57 

$8,816.62 

DCB OCE - 0024 
124

CHESTER WILLCOX & SAXBE L.L.P. 

Attorneys and Counselors at Law 

Tolephone 614/_ 65 East State Street Suite 1000, Columbus, Ohio 43215~4213 

July 15, 2009 

Fax 6141221-4012 

Billing 06/30/2009 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUR AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

Invoice# 117109 DeB 

Our File 13292 00024 

$8,816.62 

(3,074.57) 

$5,742.05 

5,070.00 

106.52 

$5,176.52 

$10,918.57 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

RETURN THIS PAGE WITH PAYMENT 

DCB OCE - 0025 
125

CHESTER WILLCOX & SAXBE L.L.P. 

Attorneys and Counselors at Law 

Telephone 614_ 65 East State Street Suite 1000, Columbus, Ohio 43215~4213 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

RESIDENT SCHOLAR 

July 15, 2009 

Billed through 

Invoice Number 

Ourfile# 

F.E.!. No. 31·4422499 

06/30/2009 

117109 

13292 00024 

1025 CONNECTICURAVE., NW., SUITE 1000 

WASHINGTON, DC 20036 REDACTED 

Schmidt v. Krikorian 

Balance forward as of invoice June 15, 2009 

Payments received since last invoice 

Past Due Balance (Disregard if Paid) 

$8,816.62 

(3,074.57) 

$5,742.05 

DCB aCE - 0026 
126

13292 00024 Invoice# 117109 

REDACTED 

EXPENSES 

06/30/2009 DELIVERY CHARGE 

06/30/2009 PHOTOCOPY SERVICE @ $.18 

TOTAL DISBURSEMENTS 

SUMMARY OF BILLED AMOUNTS 

DCB BREY, DONALD C. 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

15.60 hrs 325.00 Ihr 

15:60 hrs 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

Page 2 

14.00 

92.52 

$106.52 

$5,070.00 

. $5,070.00 

5,070.00 

106.52 

$5,176.52 

$5,742.05 

$10,918.57 
127

CHESTER WILLCOX&-rSAXBE ATTORNEYS & COUNSELORS AT I-AW 

Telephone 614_ 65 East State Street Suite 1000, Columbus, Ohio 43215·4213 Fax 6141221,4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

Late Payment Charge 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

August 14, 2009 

Billing 07/31/2009 

Invoice# 117933 DCB 

Our File # 13292 00024 

$10,918.57 

(0.00) 

$10,918.57 

20,835.50 

3,431.99 

85.66 

$24,353.15 

$35,271.72 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

RETURN THIS PAGE WITH PAYMENT 

DeB aCE - 0028 
128

CHESTER WILLCOX&~AXBE ATTORN~YS & COUNSELORS AT LAW 

PH. (614_ 65 East State Street Suite 1000, Columbus, Ohio 43215·4213 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

RESIDENT SCHOLAR 

August 14, 2009 

Billed through 

Invoice Number 

Ourflle# 

FIN 31·4422499 

0713112009 

117933 

13292 00024 

1025 CONNECTICUT AVE" N.W ... SUITE 1000 

WASHINGTON. DC 20036 . REDACTED 

Schmidt v. Krikorian 

Balance forward as of invoice July 15, 2009 

Payments received since last invoice 

Past Due Balance (Disregard if Paid) 

$10,918.57 

(0.00) 

$10,918.57 
129

13292 00024 Invoice# 11 7933 Page 2 

REDJJC.TED 
130

13292 00024 Invoice# 117933 

IlfDllCTED 

EXPENSES 

07/31/2009 MILEAGE 

07/31/2009 PHOTOCOPY SERVICE @ $.18 

07/31/2009 TRANSCRIPT 

TOTAL DISBURSEMENTS 

SUMMARY OF BILLED AMOUNTS 

Page 3 

268.40 

198.54 

2,965.05 

$3,431.99 

DCB 

MEL 

BREY, DONALD C. 61.70 hrs 

8.70 hr. 

70.40 hrs 

325.00 Ihr $20,052.50 

LEWIS, MARY E. - Law Clerk 90.00 Ihr $783.00 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

LATE PAYMENT CHARGE ON PAST DUE BALANCE 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

$20,835.50 

20,835.50 

3,431.99 

85.66 

$24,353.15 

$10,918,57 

$35,271.72 

DCB aCE - 0031 
131

CHESTER WILLCOX&,SAXBE ATTORNEYS & COUNSELORS AT LAVV 

Telephone 6141_ 65 East State Street Suite 1000, Columbus, Ohio 43215-4213 Fax 6141221-4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

Late Payment Charge 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

September 10, 2009 

Billing 08/31/2009 

Invoice# 118573 DCB 

Our File # 13292 00024 

$35,271.72 

(10,918.57) 

$24,353.15 

36,867.00 

1,345.01 

51.01 

$38,263.02 

$62,616.17 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

RETURN THIS PAGE WITH PAYMENT 
132

CHESTER WILLCOX&SAXBE ATTORNEYS &. COUNSELORS AT LAVV 

PH. (614_ 65 East State Street Suite 1000, Columbus, Ohio 43215~4213 FIN 31-4422499 

Seplember 10, 2009 

Billed Ihrough 0813112009 

Invoice Number 118573 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE" N.W" SUITE 1000 

WASIIINGTON, DC 20036 

Schmidt v. Krikorian 

Ourfile# 

REDACTED 

Balance forward as of invoice August 14, 2009 

Payments received since last invoice 

Past Due Balance (Disregard if Paid) 

13292 00024 

$35,271.72 

(10,918.57) 

$24,353.15 
133

13292 00024 Invoice# 118573 Page 2 

REDACTED 

DCB aCE - 0034 
134

13292 00024 Invoice# 118573 Page 3 

llEDAl:TED 
135

13292 00024 Invoice# 118573 

REDACTED 

EXPENSES 

08/31/2009 HOTEL/MEALS WHILE TRAVELING 

08/31/2009 MILEAGE 

08/31/2009 PHOTOCOPY SERVICE @ $.18 

08/31/2009 WESTLAW RESEARCH 

TOTAL DISBURSEMENTS 

SUMMARY OF BILLED AMOUNTS 

Page 4 

368.79 

145.20 

809.10 

21.92 

$1,345.01 

DCB 

EJW 

BREY. DONALD C. 

WATTERS, ELIZABETH J. 

107.90 hrs 325.00 Ihr $35,067.50 

6.10 hrs 295.00 Ihr $1,799.50 

114.00 hrs $36,867.00 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSE811-1CURRED 

LATE PAYMENT CHARGE ON PAST DUE BALANCE 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

36,867.00 

1,345,01 

51.01 

$38,263.02 

$24,353.15 

$62,616,17 

DCB aCE - 0036 
136

CHESTER WILLCOX~AXBE ATTORNEYS &. COUNSELORS AT LAW 

Telephone 614/_ 65 East State Str •• t Suite 1000, Columbus, Ohio 43215-4213 Fax 614/221·4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDE'JT SCHOLAR 

1025 CONNECTICUT AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

Late Payment Charge. 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

October 15, 2009 

Billing 09/30/2009 

Invoice# 119254 DCB 

Our File # 13292 00024 

$62,616.17 

(0.00) 

$62,616.17 

30,132.50 

4,038.59 

363.54 

$34,534.63 

$97,150.80 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

RETURN THIS PAGE WITH PAYMENT 
137

CHESTER WILLCOX~SAXBE ATTORNEYS & COl.JNSELORS AT LAVV 

PH,(614_ 65 East State Street Suite 1000, Columbus, Ohio 43215~4213 FIN 31·4422499 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE" N,W" SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v, Krikorian 

October 15, 2009 

Billed through 09/30/2009 

Invoice Number 119254 

Our file# 13292 00024 

REDACTED 

Balance forward as of invoice September 1 0, 2009 

Payments received since last invoice 

$62,616.17 

(0,00) 

Past Due Balance (Disregard if Paid) $62,616.17 

DCB OCE - 0038 
138

\3292 00024 Invoice# 119254 Page 2 

REDACTED, 

DCB aCE - 0039 
139

13292 00024 Invoice# 119254 

,lIEDACTEO 

EXPENSES 

09/30/2009 HOTEL/MEALS WHILE TRAVELING 

09/30/2009 PHOTOCOPY SERVICE @ $.18 

09/30/2009 TRANSCRIPT 

09/30/2009 WESTLAW RESEARCH 

TOTAL DISBURSEMENTS 

Page 3 

1,291.17 

1,216.80 

1,366.55 

164.07 

$4,038.59 

DCB aCE - 0040 
140

13292 00024 lnvoice# 11 9254 

SUMMARY OF BILLED AMOUNTS 

DCB 

EJW 

DAS 

BREY. DONALD C. 

WADERS. ELIZABETH J. 

SCOD. DEBORAH A. 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

66.20 hrs 

11.50 hrs 

27.50 hrs 

105.20 hrs 

325.00 Ihr 

295.00 Ihr 

190.00 Ihr 

LATE PAYMENT CHARGE ON PAST DUE BALANCE 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

Page 4 

$21,515.00 

$3.392.50 

$5.225.00 

$30,132.50 

30.132.50 

4.038.59 

363.54 

$34,534.63 

$62,616.17 

$97,150.80 
141

CHESTER WILLCOX&SAXBE ATTORNEYS & COUNSELORS AT LA'N 

Telephone 614_ 65 East State Street 5ultel000, Columbus, Ohio 432154213 Fax 6141221.4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

Late Payment Charge 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

November 13, 2009 

Billing 10/31/2009 

Invoice# 120356 DCB 

Our File # 13292 00024 

$97,150.80 

(0.00) 

$97,150.80 

5,315.50 

5,388.81 

936.72 

$11,641.03 

$108,791.83 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

PLEASE RETURN THIS PAGE WITH PAYMENT 
142

CHESTER WILLCOX&SAXBE ATTORNeyS & COUNSELORS AT LAVI/ 

PH. (614_ 65 East state Street Suite 1000, Columbus, Ohio 43215·4213 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

November 13, 2009 

Billed through 

InvoIce Number 

Ourfile# 

FIN 31-4422499 

10/31/2009 

120356 

13292 00024 

1025 CONNECTICUT AVE .. N.W., SUITE 1000 

WASHINGTON, DC 20036 REDACTED 

Schmidt v. Krikorian 

Balance forward as of invoice October 15, 2009 

Payments received since last invoice 

Past Due Balance (Disregard if Paid) 

$97,150.80 

(0.00) 

$97,150.80 

DCB aCE - 0043 
143

13292 00024 

EXPENSES 

10/31/2009 MEALS 

10/31/2009 OVERNIGHT DELIVERY 

10/31/2009 PHOTOCOPY SERVICE@$.18 

10/31/2009 TRANSCRIPT 

10/31/2009 WESTLAW RESEARCH 

TOTAL DISBURSEMENTS 

SUMMARY OF BILLED AMOUNTS 

lnvoice# 120356 

REDACTED 

Page 2 

46.60 

64.28 

14.58 

4,632.40 

630.95 

$5,388.81 

DCB 

EJW 

DEA 

BREY, DONALD C. 

WATTERS, ELIZABETH J, 

ABBOTT, DIANE E.· Paralegal 

15.80 hr. 325.00 Ihr $5,135.00 

0.40 hr. 295.00 Ihr $118.00 

0,50 hr. 125,00 Ihr $62,50 

16.70 hr. ---'$"'5-ic,3"'15"',5"'0 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

LATE PAYMENT CHARGE ON PAST DUE BALANCE 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

5,315,50 

5,388,81 

936.72 

$11,641,03 

$97,150,80 

$108,791,83 

DCB aCE - 0044 
144

CHESTER WIllCOX-smAXBE ATTORNEtYS & COUNSELORS Ai LAW 

Talaphone 614/_ 65 East State Street Suite 1000, Columbus, Ohio 43215~4213 Fax 614/221.4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N,W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

Late Payment Charge 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

December 11, 2009 

Billing 1113012009 

Invoice# 120855 DCB 

Our File # 13292 00024 

$108,791.83 

(0.00) 

$108,791.83 

910.00 

1,199.89 

1,449,29 

$3,559.18 

$112,351.01 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

PLEASE RETURN THIS PAGE WITH PAYMENT 
145

CHESTER WILLCO~AXBE ATTORNEYS 3<. COUNSELORS AT LAVV 

PH. (614_ 65 East State Street Suite 1000, Columbus, Ohio 43215·4213 FIN 31·4422499 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE" N.w" SUITE 1000 WASHINGTON, DC 20036 

Schmidt v, Krikorian 

December 11, 2009 

Billed through 11/30/2009 

Invoice Number 120855 

Our file# 13292 00024 

REDACTED 

Balance forward as of invoice November 13, 2009 

Payments received since last invoice 

$108,791,83 

(0,00) 

Past Due Balance (Disregard if Paid) 

EXPENSES 

11/30/2009 OVERNIGHT DELIVERY 

11/30/2009 PHOTOCOPY SERVICE @ $.18 

11/30/2009 TRANSCRIPT 

TOTAL DISBURSEMENTS 

$108,791,83 

16.73 

3.96 

1,179,20 

$1,199,89 

DCB OCE - 0046 
146

13292 00024 Invoice# 120855 Page 2 

SUMMARY OF BILLED AMOUNTS 

DCB BREY, DONALD C. 2.80 hrs 

-----z:so hrs 

325.00 Ihr $910.00 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

LATE PAytvlENT CHARGE ON PAST DUE BALANCE 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

------;$"'9"10,..,.0"'"0 

910.00 

1,199.89 

1 ,449.29 

$3,559.18 

$108,791.83 

$112,351.01 
147

CHESTER WILLCOX~SAXBE ATTORNEYS & COUNSSLORS AT l..AW 

Telephone 614/_ 65 East State Street Suite 1000, Columbus, Ohio 43215·4213 Fax 614/221.4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N.W., SUITE 1000 

WASHI~GTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

January 15, 2010 

Billing 12131/2009 

Invoice# 121316 DCB 

Our File # 13292 00024 

$112,351.01 

(112,351.01) 

$0.00 

1,202.50 

1.26 

$1,203.76 

$1,203.76 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1.5%-PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

PLEASE RETURN THIS PAGE WITH PAYMENT 
148

CHESTER WIllCO:K&SAXBE ATTORNEYS & COUNSELORS AT l.AVV 

PH. (614_ 65 East State Street Suite 1000, Columbus1 Ohio 43215~4213 FIN 31·4422499 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

January 15, 2010 

Billed through 1213112009 

Invoice Number 121316 

Our me# 13292 00024 

REDACTED 

Balance forward as of invoice December 11,2009 

Payments received since last invoice 

$112,351.01 

(112,351.01) 

Past Due Balance (Disregard if Paid) $0.00 

EXPENSES 

12/3112009 PHOTOCOPY SERVICE@$.18 1.26 

DCB aCE - 0049 
149

13292 00024 Invoice# 121316 

TOTAL DISBURSEMENTS 

SUMMARY OF BILLED AMOUNTS 

DCB BREY, DONALD C. 3:70 hrs 

~hrs 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

TOTAL BALANCE DUE ON ACCOUNT 

325.00 Ihr 

Page 2 

$1.26 

$1,202.50 

$1,202.50 

1,202.50 

1.26 

$1,203.76 

$1,203.76 
150

CHESTER WILLCOXSiSAXBE ATTORNEYS & COUNSELORS AT LAW 

Telephone 6141_ 65 East Siale Sireetsuite1000, Columbus, Ohio 43215·4213 Fax 614/221·4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N.W" SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v, Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

February 12, 2010 

Billing 01131/2010 

Invoice# 121986 DCB 

Our File # 13292 00024 

$1,203.76 

(0,00) 

$1,203.76 

10,164,50 

291,64 

$10,456,14 

$11,659.90 

DUE; UPON RE;CEIPT 

LATE PAYME;NT FEE; (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

PLEASE RETURN THIS PAGE WITH PAYMENT 
151

CHESTER WILLCOX&>SAXBE ATTORNIJYS & CQUNSEL.ORS AT LAW 

PH. (614_ 65 East State Street Suite 1000, Columbus, Ohio 43215-4213 FIN 31-4422499 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

February 12, 2010 

Billed through 01/31/2010 

Invoice Number 121986 

Our file# 13292 00024 

REDACTED 

Balance forward as of invoice January 15, 2010 

Payments received since las! invoice 

$1,203.76 

(0.00) 

Past Due Balance (Disregard if Paid) $1,203.76 
152

13292 00024 Invoice# 121986 Page 2 

DCB aCE - 0053 
153

13292 00024 fuvoice# 121986 

REDACTED 

EXPENSES 

01/31/2010 DELIVERY CHARGE 

01/31/2010 PHOTOCOPY SERVICE @ $.18 

TOTAL DISBURSEMENTS 

SUMMARY OF BILLED AMOUNTS 

DCB BREY. DONALD C. 

SDM MORRISON. SARAH DAGGETT 

EJW WATTERS, ELIZABETH J. 

DAS SCOTT, DEBORAH A. 

CBM MURPHY, CHRISTOPHER B. - Law Clerk 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

26.60 hr. 

0.30 hr. 

0.40 hr. 

5.70 hr. 

1.60 hr. 

34.60 hr. 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

325.00 

285.00 

295.00 

200.00 

110.00 

Ihr 

Ihr 

Ihr 

Ihr 

Ihr 

Page 3 

58.00 

233.64 

$291.64 

$8,645.00 

$85.50 

$118.00 

$1,140.00 

$176.00 

$10,164.50 

10,164.50 

291.64 

$10,456.14 

$1,203.76 

$11,659.90 

DCB OCE - 0054 
154

CHESTER WILLCOX~AXB E ATTORNgyS & COt.JNSELORS AT LAW 

T_I_phone 614/_ 65 Easl Slate Slre_tSuit_1000, Columbus, Ohio 43215·4213 Fax 614/221·4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

Late Payment Charge 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

March 12, 2010 

Billing 02/28/2010 

Invoice# 122678 DCB 

Our File # 13292 00024 

$11,659.90 

(0.00) 

$11,659.90 

9,535.50 

310.88 

18.06 

$9,864.44 

$21,524.34 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

PLEASE RETURN THIS PAGE WITH PAYMENT 

DCB aCE - 0055 
155

CHESTER WILLCOX~5SAXBE 

PH. (614_ 

ATTORNEYS & COUNSELORS AT LA\N 

65 East Stat. Street Suite 1000, Columbus, Ohio 43215-4213 

March 12, 2010 

Billed through 

Invoice Number 

Ourflle# 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

FIN 31·4422499 

02/2812010 

122678 

13292 00024 

1025 CONNECTICUT AVE., N.W" SUITE 1000 

WASHINGTON, DC 20036 REDACTED 

Schmidt v. Krikorian 

Balance forward as of invoice February 12, 2010 

Payments received since last invoice 

Past Due Balance (Disregard if Paid) 

$11,659.90 

(0.00) 

$11,659.90 
156

132q? 00024 Invoice# 122678 Page 2 

REDACTED 
157

13292 00024 Invoice# 122678 

EXPENSES 

02/23/2010 U.S. DISTRICT COURT,; Invoice # 1:10-cv-00103; FILING 

FEE PRO HAC VICE 

02/28/2010 DELIVERY CHARGE 

02/28/2010 .LEXIS RESEARCH 

02/28/2010 PHOTOCOPY SERVICE@ $.18 

02/28/2010 OUTSIDE PHOTOCOPY SERVICE 

02/28/2010 WESTLAW RESEARCH 

TOTAL DISBURSEMENTS 

SUMMARY OF BILLED AMOUNTS 

Page 3 

200.00 

32.50 

7.41 

64.62 

3.10 

3.25 

$310.88 

DCB 

JHB 

BREY, DONALD C. 

BEEHLER, JASON H. 

28.70 hr. 32S.00 Ihr $9,327.S0 

1.30 hrs 160.00 Ihr $208.00 

30.00 hrs -'$"'9",S3""'Sc;o.S'"0 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

LATE PAYMENT CHARGE ON PAST DUE BALANCE 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

9,535.50 

310.88 

18.06 

$9,864.44 

$11,659.90 

$21,524.34 
158

CHESTER WIllCOX&SAXBE ATTORNE:YS 8< COUNSELORS AT LA'N 

Telephone 614_ 65 East State Street Suite 1000, Columbus, Ohio 43215·4213 Fax 6141221.4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N.W .• SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

April 19. 2010 

Billing 

Invoice# 

Our File # 

DUE UPON RECEIPT 

03/31/2010 

123392 DCB 

13292 00024 

$21,524.34 

(21,524,34) 

$0.00 

2,632.50 

122.12 

$2,754.62 

$2,754.62 

LATE PAYMENT FEE (1.5%-PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE Of INVOICE. 

PLEASE RETURN THIS PAGE WITH PAYMENT 

DCB OCE - 0059 
159

CHESTER WILLCO~SAXBE 

PH,(614_ 

A'TTORNEYS &"COUNSELORS AT LA\N 

65 East State Street Suite 1000, Columbus, Ohio 43215·4213 

April 19, 2010 

Billed through 

Invoice Number 

Ourfite# 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

FIN 314422499 

03131/2010 

123392 

13292 00024 

1025 CONNECTICUT AVE" N,W" SUITE 1000 

WASHINGTON, DC 20036 REDACTED 

Schmidt v, Krikorian 

Balance forward as of invoice March 12, 2010 

Payments received since last invoice 

Past Due Balance (Disregard if Paid) 

EXPENSES 

03/31/2010 MILEAGE 

03/3112010 PHOTOCOPY SERVICE @ $,18 

0313112010 PARKING 

TOTAL DISBURSEMENTS 

$21,524,34 

(21,524.34 ) 

$0.00 

107,50 

1,62 

13,00 

$122,12 
160

13292 00024 Invoice# 123392 

SUMMARY OF BILLED AMOUNTS 

DCB BREY, DONALD C. 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

8.10 hr. 

--a:1O hr. 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

TOTAL BALANCE DUE ON ACCOUNT 

325.00 Ihr 

Page 2 

$2,632.50 

$2,632.50 

2,632.50 

122,12 

$2,754,62 

$2,754.62 

DCB aCE - 0061 
161

CHESTER WILLCO~SAXBE ATTORN8YS ~ COUNSELORS AI LAW 

Telephone 614/_ 65 East State Street Suite 1000, Columbus, Ohio 43215·4213 Fax 614/221.4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

May 14, 2010 

Billing 

!nvoice# 

Our File # 

DUE UPON RECEIPT 

04/30/2010 

124114 DCB 

13292 00024 

$2,754.62 

(0.00) 

$2,754,62 

1,173.50 

20.70 

$1,194,20 

$3,948,82 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

PLEASE RETURN THIS PAGE WITH PAYMENT 
162

CHESTlER WILLCOX"-LSAXBE ATTORNEYS &. C:;:;OUNSEl..ORS AT LAW 

PH,(614)_ 65 East State Street Suite 1000, Columbus, Ohio 43215·4213 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

May 14, 2010 

flilled through 

Invoice Number 

Ourfile# 

RESIDENT SCHOLAR 

10"5 CONNECTICUT AVE" N.W" SUITE 1000 WASHINGTON, DC 20036 REDACTED 

Schmidt v, Krikorian 

Balance forward as of invoice April 1 g, 2010 

Payments received since last invoice 

Past Due Balance (Disregard if Paid) 

FIN 31·4422499 

0413012010 

124114 

13292 00024 

$2,754,62 

(0,00) 

$2,754.62 
163

13292 00024 Invoice# 124114 Page 2 

REDACTED EXPENSES 

04/30/2010 PHOTOCOPY SERVICE@ $.18 

TOTAL DISBURSEMENTS 

SUMMARY OF BILLED AMOUNTS 

DCB 

CBM 

BREY, DONALD C. 

MURPHY, CHRISTOPHER B. - Law Clerk 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

2.90 hr. 

2.10 hrs 

-----s.oo hrs 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Di.sregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

20.70 

$20.70 

325.00 thr $942.50 

110.00 thr $231.00 

-"$1"',1"73"'.5"'"0 

1,173.50 

20.70 

$1,194.20 

$2,754.62 

$3,948.82 

DCB aCE - 0064 
164

CHESTER WILLCOX&SAXBE ATTORNEYS &; COUNSELORS AT LAVII 

Telephone 6141_ 65 East State Street Suite 1000, Columbus, Ohio 43215·4213 Fax 614/221·4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard If Paid) 

Total Fees 

Tofal Expenses 

Late Payment Charge 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

June 11,2010 

Billing 

Invoice# 

Our File# 

DUE UPON RECEIPT 

05/31/2010 

124974 DCB 

13292 00024 

$3,948,82 

(2,754.62) 

$1,194.20 

2,600.00 

51.27 

41.32 

$2,692.59 

$3,886,79 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE, 

PLEASE RETURN THIS PAGE WITH PAYMENT 
165

CHESTER WILLCOX®BAXBE ATTORN£:;:YS & COUNSELORS AT LAVV 

PH. (614_ 65 East State Streot Suite 1000, Columbus, Ohio 43215.4213 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

June 11,2010 

Billed through 

Invoice Number 

Ourfile# 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE .. N.W., SUITE 1000 

WASHINGTON, DC 20036 REDACTED 

Schmidt v. Krikorian 

EXPENSES 

Balance fOlWard as of invoice May 14, 2010 

Payments received since last invoice 

Past Due Balance (Disregard if Paid) 

05/31/2010 LEXIS RESEARCH 

FIN 31·4422499 

05/3112010 

124974 

13292 00024 

$3,948.82 

(2,754.62) 

$1,194.20 

5.65 

DCB OCE - 0066 
166

13292 00024 Invoice# 124974 

EXPENSES 

05/31/2010 PACER RESEARCH SERVICE 

05/31/2010 PHOTOCOPY SERVICE @$.18 

TOTAL DISBURSEMENTS 

SUMMARY OF BILLED AMOUNTS 

DCB BREY, DONALD C. 8,00 hr. 

------s.oo hrs 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

325.00 Ihr 

LATE PAYMENT CHARGE ON PAST DUE BALANCE 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

Page 2 

18.80 

26.82 

$51.27 

$2,600.00 

$2,600.00 

2,600.00 

51.27 

41,32 

$2,692.59 

$1,194,20 

$3,886,79 

DCB OCE - 0067 
167

CHESTER WIlLCOX&1SAXBE ATTORNEYS & COUNS~LORS AT LAVV 

Telephone 6141_ 65 East State Streot Suito 1000, Columbus, Ohio 43215·4213 fax 6141221·4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE" N,W" SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

July 15,2010 

Billing 

Involce# 

Our File# 

DUE UPON RECEIPT 

06/30/2010 

125608 DCB 

13292 00024 

$3,886,79 

(1,194,20) 

$2,692.59 

2,405,00 

495,74 

$2,900.74 

$5,593.33 

LATE PAYMENT FEE (1,5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

PLEASE RETURN THIS PAGE WITH PAYMENT 

DCB OCE - 0068 
168

CHESTER WILLCOX~SAXBE ATTORNEYS &. COUNSELORS AT LAVV 

PH. (614)_ 65 East State Street Suite 10001 Columbus, Ohio 43215·4213 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

July 15, 2010 

Billed through 

Invoice Number 

Ourfile# 

REDACTED 

Baianceforward as of invoice June 11, 2010 

Payments received since last invoice 

Past Due Balance (Disregard if Paid) 

FIN 31-4422499 

06/30/2010 

125608 

13292 00024 

$3,886.79 

(1,194.20) 

$2,692.59 

DCB OCE - 0069 
169

13292 00024 Invoice# 125608 

EXPENSES 

0610712010 CLERK OF COURTS, CLERMONT; Invoice # 06072010; 

FILING FEE 

0613012010 DELIVERY CHARGE 

0613012010 PHOTOCOPY SERVICE @ $.18 

TOTAL DISBURSEMENTS 

SUMMARY OF BILLED AMOUNTS 

DeB BREY, DONALD e. 7.40 hrs 

~hrs 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

325.00 thr 

Page 2 

200.00 

216.00 

79.74 

$495.74 

$2,405.00 

$2,405.00 

2,405.00 

495.74 

$2,900.74 

$2,692.59 

$5,593.33 
170

CHESTER WILLCOXSiSAXBE ATTORNEYS & COUNSELORS A, LAW 

Telephone 614/_ 65 East State Street Suite 1000, Columbus, Ohio 43215·4213 Fax 614/221·4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., NW., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

Adjustments Applied 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

August 13, 2010 

Billing 07/31/2010 

Invoice# 126852 DCB 

Our File # 13292 00024 

$5,593.33 

(5,552.01) 

(-41.32) 

$0.00 

877.50 

4.96 

$882.46 

$882.46 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

'PLEASE RETURN THIS PAGE WITH PAYMENT 
171

CHESTlER WILLCOX~SAXBE A1TORN""YS &. COUNSELORS AT LAVoJ 

PH,(614_ 65 East Slato Stroot Suit01000, Columbus, Ohio 43215-4213 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

RESIDENT SCHOLAR 

August 13, 2010 

Billed through 

Invoice Number 

Ourfile# 

FIN 31-4422499 

07/31/2010 

126852 

13292 00024 

1025 CONNECTICUT AVE" NW" SUITE 1000 

WASHINGTON, DC 20036 REDACTED 

Schmidt v, Krikorian 

EXPENSES 

Balance forward as of invoice July 15, 2010 

Payments received since last invoice 

AIR adjustments made since last invoice 

Past Due Balance (Disregard if Paid) 

07/31/2010 PACER RESEARCH SERVICE 

$5,593.33 

(5,552,01) 

(-41.32) 

$0.00 

4,96 
172

13292 00024 Invoice# 126852 Page 2 

TOTAL DISBURSEMENTS $4.96 

SUMMARY OF BILLED AMOUNTS 

DCB BREY, DONALD C. 2.70 hrs 325.00 Ihr $877.50 

-va hrs ---;$~87==7,c:,5"-0 

TOTAL. PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

TOTAL BALANCE DUE ON ACCOUNT 

877.50 

4.96 

$882.46 

$882.46 
173

CHESTER WIllCOX&SAXBE ATTORN~YS R< COUNSELORS AT LAV\f 

Telephone 614/_ 65 Ea~t State Street Suite 1000, Columbus, Ohio 43215·4213 Fax 6141221-4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE" N,W" SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v, Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

September 13, 2010 

Billing 08/31/2010 

Involce# 127133 DCB 

Our File # 13292 00024 

$882.46 

(0,00) 

$882,46 

130,00 

49.44 

$179.44 

$1,061,90 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1,5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE, 

PLEASE RETURN THIS PAGE WITH PAYMENT 

DCB OCE - 0074 
174

CHESTlER WILLCOX&SAXBE ATTORNEYS &. COUNSELORS AT LAVI/ 

pH. (614l_ 65 East State Street S~ite 1000, Columbus, Ohio 43215-4213 FIN 31·4422499 

September 13, 2010 

Billed through 08/31/2010 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

RESIDENT SCHOLAR 

1026 CONNECTICUT AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

Invoice Number 127133 

Our file# 13292 00024 

REDACTED 

Balance forward as of invoice August 13, 2010 

Payments received since last invoice 

$882.46 

(0.00) 

Past Due Balance (Disregard if Paid) $882.46 

EXPENSES 

08/31/2010 CONFERENCE CALI:: 49.44 

TOTAL DISBURSEMENTS $49.44 

DCB aCE . 0075 
175

13292 00024 Invoice# 127133 Page 2 

SUMMARY OF BILLED AMOUNTS 

DCB BREY, DONALD C. 0.40 hrs 

--0:40 hrs 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

325.00 Ihr _---;$cc13~0~'070 

$130.00 

130.00 

49.44 

$179.44 

$882.46 

$1,061.90 
176

CHESTER WIIICOX~SAXBE ATTORNI::YS & COUNSr:;:LORS AT LAW 

Telephone 6141_ 65 East State Street Suite 1000, Columbus, Ohio 432154213 Fax 6141221·4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard If Paid) 

Total Fees 

Total Expenses 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

October 14, 2010 

Billing 09/30/2010 

Invoice# 128317 DCB 

Our File # 13292 00024 

$1,061.90 

(882.46) 

$179.44 

9,753.00 

481.52 

$10,234.52 

$10,413.96 

DUE upoN RECEIPT 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. . 

PLEASE RETURN THIS PAGE WITH PAYMENT 
177

CHESTER WILLCOX:g---£SAXBE ATTORNE':YS &. COUNSELORS AT LAVV 

PH. (614_ 65 East State Street Suite 100Q, Columbus, OhIo 43215-4213 FIN 31·4422499 

October 14, 2010 

Billed through 09/30/2010 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N,W .. SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v, Krikorian 

Invoice Number 128317 

Our me# 13292 00024 

REDACTED 

Balance forward as of invoice September 13, 2010 

Payments received since last invoice 

$1,061,90 

(882.46) 

Past Due Balance (Disregard if Paid) $179.44 
178

13292 00024 Invoice# 128317 

REDACTED 

EXPENSES 

0913012010 HOTELIMEALS WHILE TRAVELING 

0913012010 MILEAGE 

0913012010 PHOTOCOPY SERVICE FOR THE MONTH @ $.18 

0913012010 OUTSIDE PHOTOCOPY SERVICE 

TOTAL DISBURSEMENTS 

Page 2 

235.86 

155.50 

87.66 

2.50 

$481.52 

DCB aCE - 0079 
179

13292 00024 Invoice# 128317 

SUMMARY OF BILLED AMOUNTS 

DCB BREY, DONALD C. 23.20 hrs 

SDM MORRISON, SARAH DAGGETT 2.00 hrs 

EJW WATTERS, ELIZABETH J. 4.60 hrs 

CBM MURPHY, CHRISTOPHER B. - Law Clerk 2.60 hrs 

~hrs 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

325.00 

285.00 

295.00 

110.00 

Ihr 

Ihr 

Ihr 

Ihr 

Page 3 

$7,540.00 

$570.00 

$1,357.00 

$286.00 

$9,753.00 

9,753.00 

481.52 

$10,234.52 

$179.44 

$10,413.96 
180

CHESTER WILLCOX&"SAXBE ATTORNRYS 8< COUNSELORS AT LAW 

'felephone 614_ 65 East State Street Suite 1000, Columbus, Ohio 43215·4213 Fax 614/221·4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since las! invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

November 11, 2010 

Billing 1013112010 

Invoice# 128728 DCB 

Our File # 13292 00024 

$10,413.96 

(10,413.96) 

$0.00 

11,358.50 

199.30 

$11,557.80 

$11,557.80 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1.5%"PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

PLEASE RETURN THIS PAGE WITH PAYMENT 

DCB DCE - 0081 
181

CHESTIER WILLCOX~SAXBE ATTORNEYS & COUNSELORS At LAW 

PH. (614_ 65 East State Str •• t Suit. 1000, Columbus, Ohio 43215·4213 FIN 31·4422499 

November ii, 2010 

Billed through 1013112010 

Invoice Number 128728 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

Ourfile# 13292 00024 

RESIDENT SCHOLAR 

10?5 CONNECTICUT AVE .• NoW .• SUITE 1000 

WASHINGTON. DC 20036 REDACTED 

Schmidt v. Krikorian 

Balance forward as of invoice October 14, 2010 

Payments received since last invoice 

Past Due Balance (Disregard if Paid) 

$10,413.96 

(10,413.96) 

$0.00 
182

13292 00024 Invoice# 128728 Page 2 

REDACTED 
183

13292 00024 Tm,oice# 128728 

REOAGTED 

EXPENSES 

10/31/2010 PHOTOCOPY SERVICE FOR THE MONTH @ $.18 

10/31/2010 TRANSCRIPT 

10/31/2010 WESTLAW RESEARCH 

TOTAL DISBURSEMENTS 

Page 3 

117.90 

70.00 

11.40 

$199.30 
184

13292 00024 Invoice# 128728 

SUMMARY OF BILLED AMOUNTS 

DCB BREY, DONAI,D C. 

SDM MORRISON, SARAH DAGGETT 

EJW WATTERS, ELiZABETK J. 

CBM MURPKY, CHRISTOPHER B. - Law Clerk 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

14.00 hrs 

4.80 hr$ 

17.10 hrs 

3.60 hr$ 

39,50 hrs 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

TOTAL BALANCE DUE ON ACCOUNT 

325.00 

285.00 

295.00 

110.00 

Ihr 

Ihr 

Ihr 

Ihr 

Page 4 

$4,550.00 

$1,368.00 

$5,044.50 

$396.00 

$11,358.50 

11,358.50 

199.30 

$11,557.80 

$11,557.80 
185

CHESTER WILLCOX&SAXBE ATTORNF.:YS & COUNSELORS AT LAW 

Telephone 6141_ 65 East State Streel Suite 1000, Columbus, Ohio 43215-4213 Fax 6141221-4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

C/O BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N.W., SUITE 1000 

WASHINGTON. DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

December 10, 2010 

Billing 11130/2010 

Invoice# 129453 DCB 

Our File # 13292 00024 

$11,557.80 

(0.00) 

$11,557.80 

18,688.50 

1,331.36 

$20,019.86 

$31,577.66 

PUS UPON RECEIPT 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

PLEASE RETURN THIS PAGE WITH PAYMENT 

DeB OCE - 0086 
186

CHESTlER WIlLCOX&SAXBE ATTORNgyS &. COUNSELORS AT LAW 

PH. (614_ 65 East State Street Suite 1000, Columbus, Ohio 43215·4213 FIN 31-4422499 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N.W" SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

December 10, 2010 

Billed through 1113012010 

Invoice Number 129453 

Our file# 13292 00024 

REDACTED 

Balance forward as of invoice November 11,2010 

Payments received since last invoice 

$11,557.80 

(0.00) 

Past Due Balance (Disregard if Paid) $11,557.80 

DCB OCE - 0087 
187

13292 00024 Invoice# 129453 Page 2 

REDACTED 
188

13292 00024 Invoice# 129453 Page 3 

REDACTED 

DCB aCE - 0089 
189

13292 00024 

EXPENSES 

11/30/2010 CONFERENCE CALL 

11130/2010 DELIVERY CHARGE 

11130/2010 MILEAGE 

11/3012010 OVERNIGHT DELIVERY 

Invoice# 129453 

REDACTED 

11/30/2010 PHOTOCOPY SERVICE FOR THE MONTH @$.18 

1113012010 TRANSCRIPT 

11/3012010 WESTLAW RESEARCH 

TOTAL DISBURSEMENTS 

Page 4 

53.68 

216.00 

145.50 

109.46 

222.66 

402.50 

181.56 

$1,331.36 

DCB aCE - 0090 
190

13292 00024 lnvoice# 129453 

SUMMARY OF BILLED AMOUNTS 

DCB 

EJW 

BREY, DONALD C. 

WATTERS, ELIZABETH J. 

35.90 hrs 

23.80 hrs 

~hrs 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

325.00 thr 

295.00 thr 

Page 5 

$11,667.50 

$7,021.00 

$18,688.50 

18,688.50 

1,331.36 

$20,019.86 

$11,557.80 

$31,577.66 
191

CHESTER WILLCO~SAXBE ATI'ORN~YS 8< C;:::OUNSELOKS AT LAW 

Telephone 6141_ 65 East state Street Suite 1000, Columbus, Ohio 43215-4213 Fax 6141221·4012 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE., N.W., SUITE 1000 

WASHINGTON, DC 20036 

Schmidt v. Krikorian 

BALANCE FORWARD 

Payments received since last invoice 

PAST DUE BALANCE (Disregard if Paid) 

Total Fees 

Total Expenses 

Late Payment Charge 

TOTAL NEW CHARGES 

TOTAL BALANCE DUE ON ACCOUNT 

January 17, 2011 

Billing 12/31/2010 

Invoice# 130554 DCB 

Our File # 13292 00024 

$31,577.66 

(0.00) 

$31,577.66 

4,830.00 

90.52 

473.66 

$5,394.18 

$36,971.84 

DUE UPON RECEIPT 

LATE PAYMENT FEE (1.5% PER MONTH) CHARGED ON ALL UNPAID BALANCES 

OVER 30 DAYS FROM DATE OF INVOICE. 

PLEASE RETURN THIS PAGE WITH PAYMENT 
192

CHESTER WILLCOXs:~SAXBE ATTORNEYS &. COUNSELORS AT LAW 

PH. (614)_ 65 East State Street Suite 1000, Columbus, Ohio 43215·4213 

TURKISH AMERICAN LEGAL DEFENSE FUND 

CIO BRUCE FEIN 

RESIDENT SCHOLAR 

1025 CONNECTICUT AVE .. N.W .. SUITE 1000 

WASHINGTON, DC 20036 

Schmid! v. Krikorian 

January 17, 2011 

Billed through 

Invoice Number 

Ourfile# 

REDACTED 

Balance forward as of invoice December 10, 2010 

Payments received since last invoice 

Pas! Due Balanco (Disregard if Paid) 

FIN 31·4422499 

12/31/2010 

130554 

13292 00024 

$31,577.66 

(0.00) 

$31,577.66 
193

13292 00024 Invoice# 130554 

REDACTED 

EXPENSES 

12/31/2010 LEXIS RESEARCH 

12/31/2010 OVERNIGHT DELIVERY 

12/31/2010 PHOTOCOPY SERVICE FOR THE MONTH @ $.18 

TOTAL DISBURSEM_ENTS 

Page 2 

3.41 

14.39 

72.72 

$90.52 
194

13292 00024 Invoice# 130554 Page 3 

SUMMARY OF BILLED AMOUNTS 

DCB 

EJW 

BREY, DONALD C. 

WATTERS, ELIZABETH J. 

13.50 hrs 

1.50 hrs 

15:00 hrs 

325.00 Ihr $4,387.50 

295.00 Ihr _--=$",44",2~.5~O 

$4,830.00 

TOTAL PROFESSIONAL SERVICES 

TOTAL EXPENSES INCURRED 

LATE PAYMENT CHARGE ON PAST DUE BALANCE 

TOTAL OF NEW CHARGES FOR THIS INVOICE 

PLUS PAST DUE BALANCE (Disregard if Paid) 

TOTAL BALANCE DUE ON ACCOUNT 

4,830.00 

90.52 

473.66 

$5,394.18 

$31,577.66 

$36,971.84 

DCB OCE - 0095 
195

EXHIBIT 12 

197

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the I 10th Congress as Amended 

INRE: 

REVIEW No .. 

DATE 

LOCATION 

TIME: 

PARTICIPANTS: 

OFFICE OF CONGRESSIONAL ETHICS 

UNITED STATES HOUSE OF REPRESENTATIVES 

MEMORANDUM OF INTERVIEW 

Representati ve Schmidt's Chief of Statf 

11-6574 

April 6, 2011 

425 3,d St., SW 

Washington, DC 20024 

2:00 p.m. to 2:55 p.m. (approximately) 

Kedric L. Payne 

Paul J. Solis 

SUMMARY: The OCE requested an interview with Representative Schmidt's Chief of Staff, 

who is now her former Chief of Staff, on April 6, 2011, and he consented to an interview. 

Representative Jean Schmidt, who is a Member of the United States House of Representatives 

and represents the 2nd District of Ohio. Representative Schmidt's Chief of Staff made the 

following statements in response to our questioning: 

1. The witness was given an 18 USC § 1001 warning and consented to an interview. He 

signed a written acknowledgement of the warning, which will be placed in the case file in 

this review. 

2. The witness is currently a partner at BKM Consulting, which provides various services to 

political campaigns 

3. He has been employed there since approximately May 20 I 0, which is when he left his 

employment with Representative Schmidt. 

4. He became employed with Representative Schmidt shortly after she was elected in 2005. 

He served as her Chief of Statf from that time until he left in 20 I O. As Chief of Staff, the 

witness supervised all functions of the congressional office 

5. Prior to working for Representative Schmidt, the witness worked for at least three other 

House Members including Representative Kevin DeWine. 

6. The witness told the OCE that he volunteered for Representative Schmidt's campaign 

committee, but the campaign never employed him. 

7. The witness first met David Krikorian in Representative Schmidt's office in 2006 or 

2007. The witness told the OCE that Mr. Krikorian came to the office claiming he was 

the President of the Ohio Armenian Association. 

MOl - Page 1 of4 OFFICE OF CONGRESSIONAL ETHICS 
198

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the I 10th Congress as Amended 

8. Mr. Krikorian came to the office to ask Representative Schmidt to support the Armenian 

genocide resolution. During the meeting with Representative Schmidt, Mr. Krikorian 

became belligerent because Representative Schmidt would not commit to voting for the 

resolution. 

9. The witness told the OCE that in 2008 Mr. Krikorian campaigned against Representative 

Schmidt and constantly attacked her in the Armenian media. 

10. During the week before the election in November 2008, Mr. Krikorian put pamphlets on 

cars at Representative Schmidt's church. The pamphlets criticized Representative 

Schmidt and included allegations that she accepted "blood money" from the Turkish 

government. These types of statements occurred after the election as well. 

11. As a result ofMr. Krikorian's pamphlets and other statements that he made about 

Representative Schmidt, the witness and Representative Schmidt began considering 

possible legal actions against Mr. Krikorian following the election in November 2008. 

The witness told the OCE that he and Representative Schmidt took no action until 

January 2009. 

12. In January 2009, Mr. Krikorian continued to make public statements about 

Representative Schmidt 

13. The witness was familiar with the Ohio Election Commission ("OEC") and its ability to 

adjudicate false statements partly because Mr. Krikorian had filed complaints against 

Representative Schmidt with the OEC. 

14. During the first quarter of2009, Bruce Fein called the witness and said that he wanted to 

help Representative Schmidt pursue legal action against Mr. Krikorian and said he 

worked for the Turkish American Legal Defense Fund ("TALDF"). The witness knew 

Bruce Fein from his work with Representative DeWine Mr. Fein then visited 

Representative Schmidt's office to meet. 

15. The witness told the OCE that Mr. Fein suggested that the legal fee arrangement should 

be a contingency fee. Mr. Fein suggested that Representative Schmidt could sue Mr. 

Krikorian for millions of dollars based on his statements about her. 

16. The witness was not certain whether the services could be provided under a contingency 

fee based on House ethics rules and federal election law He contacted the Federal 

Election Commission ("FEC"), the House General Counsel's Office, and the House 

Committee on Ethics to get approval of the arrangement for legal services. 

MOl - Page 2 01'4 OFFICE OF CONGRESSIONAL ETHICS 
199

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the I 10th Congress as Amended 

17. The witness explained to the OCE that Mr. Fein "never" talked about providing legal 

services at no charge and "delinitely wanted to do a contingency fee." Mr. Fein was the 

first person to suggest a contingency fee. 

18. The witness knew Mr. Fein because Mr. Fein had previously worked for Representative 

Mike DeWine. The witness had worked for Representative DeWine's campaign. 

19. The witness also knew Lincoln McCurdy of the Turkish Coalition of America ("TCA") 

Mr. McCurdy had visited the witness in Representative Schmidt's office to lobby him on 

the Armenian genocide resolution. He met Mr. McCurdy in 2007 or 2008. 

20. The witness never discussed the possibility of filing a complaint against Mr. Krikorian 

with Mr. McCurdy. 

21. Although he was waiting for ethics approval on the legal fees, he did not instruct Bruce 

Fein to delay filing the complaint with the OEC. The witness stated that at the time he 

did not know who would pay for the services, but Representative Schmidt wanted to go 

to court. The witness told the OCE that if the legal services were not approved by the 

Committee on Ethics he expected that Representative Schmidt would use personal funds 

to pay for the legal services. 

22. The FEC told him that campaign funds could be used to pay for the legal services if the 

Committee on Ethics approved such use. 

23. The witness contacted the Committee on Ethics and had numerous conversations with the 

stalf about how to draft a letter requesting approval of the legal services. 

24. The witness asked whether Representative Schmidt could pay for legal expenses with 

campaign money or have a contingency fee agreement. These conversations lasted 

several weeks to months. 

25. The Committee on Ethics explained to him the possibility of establishing a legal expense 

fund At that time, the witness' personal understanding was that legal expense funds had 

never been used other than for defense issues. However, the Committee on Ethics' 

counsel told him that she thought the fund could be used for Representative Schmidt's 

situation as well. 

26. The witness told the OCE that the Committee on Ethics counsels told him not to accept 

any bill for the legal services during this time. 

27. The witness' first formal request for Committee on Ethics approval of the legal fees is in 

a letter dated September 17, 2009 (Schmidt_0029). He drafted the letter to the 

MOl - Page 3 of4 OFFICE OF CONGRESSIONAL ETHICS 
200

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the I 10th Congress as Amended 

Committee on Ethics on behalf of Representative Schmidt requesting approval of the 

legal fees. 

28. When asked why there was a time lapse between the first meeting with Mr. Fein and the 

September 17, 2009 request, the witness stated that he was waiting for the Committee on 

Ethics to provide him with the final language for the request letter. 

29. In response to the letter, the Committee on Ethics asked the witness for information about 

the amount of hours the attorneys had worked on the legal matters. 

30. As a result, the witness wrote a letter to the Committee on Ethics, dated October 8, 2009 

(Schmidt_ 0031), explaining that the attorneys had worked "just shy of 200 hours" 

31. The witness also provided the Committee on Ethics with a letter from Bruce Fein to 

Representative Schmidt stating that the attorneys agreed to represent her on a 

contingency fee basis The witness does not know when this letter about the contingency 

fee was wri tten 

32. The witness told the OCE that he believes on January 21, 2010, he sent a letter or email 

to the Committee on Ethics to amend the request for approval of a contingency fee He 

said that the Committee on Ethics advised him that the approval of the legal services 

could happen quicker if he removed the request for a contingency fee. 

33. He explained that the TALDF attorneys provided legal services for the appeal of the OEC 

matter as part of the representation in filing the complaint with the OEC 

34. T ALDF submitted an amicus brief on behalf of Representative Schmidt in federal court 

in Ohio without the witness knowing that the brief was going to be filed. He was not 

alerted to the filing until after it had been done 

35. Although the witness received the advisory opinion from the Committee on Ethics in 

February 2010, he was not involved in establishing a legal expense fund. He does not 

know why the request for approval oflegal expense fund was not sent to the Committee 

on Ethics until July 2010. He explained that he was no longer employed with 

Representative Schmidt by July 2010. 

This memorandum was prepared on April 7, 20 II, based on the notes that the OCE staff 

prepared during the interview with the witness on April 6, 2011. I certify that this memorandum 

contains all pertinent matter discussed with the witness on April 6, 2011. 

Kedric L. Payne 

Investigative Counsel 

MOl - Page 4 01'4 OFFICE OF CONGRESSIONAL ETHICS 
201

EXHIBIT 13 

203

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the I 10th Congress as Amended 

INRE: 

REVIEW No .. 

DATE 

LOCATION 

TIME: 

PARTICIPANTS: 

OFFICE OF CONGRESSIONAL ETHICS 

UNITED STATES HOUSE OF REPRESENTATIVES 

MEMORANDUM OF INTERVIEW 

Representative Jean Schmidt 

11-6574 

March 31,2011 

2464 Rayburn HOB 

Washington, DC 20515 

10:40 a.m. to 11:40 a.m. (approximately) 

Kedric L. Payne 

Paul J. Solis 

Joe Jansen 

SUMMARY: Representative Jean Schmidt is a Member of the United States House of 

Representatives and represents the 2nd District of Ohio The OCE requested an interview with 

Representative Schmidt on March 31, 2011, and she consented to an interview. Representative 

Schmidt (the "witness") made the following statements in response to our questioning: 

1. The witness was given an 18 USC § 1001 warning and consented to an interview. She 

signed a written acknowledgement of the warning, which will be placed in the case file in 

this review. 

2. The witness told the OCE that she decided that she wanted to file a complaint with the 

Ohio Election Commission ("OEC") against Me Krikorian in November 2008. This 

decision was the result of an extended period of time of Me Krikorian making public 

statements criticizing the witness. At that point the witness felt she had to do something 

about Mr. Krikorian's statements. 

3. She knew Bruce Fein from her years of serving in Congress. Me Fein was aware of Mr. 

Krikorian's public statements about the witness. He offered the legal services of the 

Turkish American Legal Defense Fund ("T ALDF") to assist the witness with the 

complaint against Me Krikorian She could not recall how or when these discussions 

with Me Fein began. 

4. The witness has known Lincoln McCurdy, president of the Turkish Coalition of America 

("TCA"), for about four or five years from his work on Capitol Hill. The witness stated 

that she did not have a discussion with Me McCurdy about TALDF's legal representation 

but does not know whether her previous Chief of Staff had such discussions. 

MOl - Page 1 01'3 OFFICE OF CONGRESSIONAL ETHICS 
204

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the I 10th Congress as Amended 

5. The witness was familiar with the TCA through the Congressional Turkish Caucus, 

which she joined. 

6. The witness told the OCE that TALDF did not offer to provide the legal services to her 

for free. She discussed with Mr Fein the possibility of a contingency fee, but this option 

was not pursued. She is not sure why it was not pursued and she does not recall when 

these conversations occurred. 

7. The witness stated that, between her and TALDF, she was the first to discuss paying for 

the legal services. 

8. The parties also discussed the possibility of having the witnesses' campaign committee 

pay for the legal services or establish a legal expense fund. 

9. When asked if she instructed the TALDF attorneys to delay tiling the OEC complaint, the 

witness stated that she did not. 

10. The witness stated that Mr. Fein selected the local counsel, Donald Brey. She told the 

OCE that she knew of Mr. Brey for many years from his work with the Ohio Republican 

Party. She told the OCE that she did not recommend him and was surprised to learn that 

he was local counsel. 

II. The witness continues to work with the Committee on Ethics to establish a legal expense 

fund, but the issue has not been finalized because the Committee on Ethics is 

uncomfortable with the trustee that she initially selected 

12. She told the OCE that ethics advice concerning payment for the T ALDF legal expenses 

was first requested during the summer of 2009. Her then Chief of Staff, Barry Bennett, 

informally asked for this advice. The advice was requested in order to determine whether 

everything was right and proper with accepting T ALDF legal services. 

13. Later in September 2009, a formal written request was submitted to the Committee on 

Ethics. When asked why she waited until September 2009 to make the formal request, 

the witness stated that it just felt like the right time to do it. 

14. The witness received an advisory opinion from the Committee on Ethics in February 

2010. When asked why there was a delay between her receipt of the advisory opinion 

and her July 2010 request for approval ofa legal expense trust, the witness stated that she 

and Mr. Bennett were trying to select a trustee. 

15. Concerning the later legal actions taken by TALDF on her behalf, the witness stated that 

T ALDF continued to be her legal counsel because she did not want to change attorneys 

MOl - Page 2 of3 OFFICE OF CONGRESSIONAL ETHICS 
205

CONFIDENTIAL 

Subject to the Nondisclosure ProvislOns ofR. Res. 895 of the I 10th Congress as Amended 

unless necessary. The witness stated that there was an understanding that she would pay 

for all of the legal services rendered. 

16. Mr. Bennett was the primary point of contact between the witness' office and TALDF 

This memorandum was prepared on April 4, 2011, based on the notes that the OCE staff 

prepared during the interview with the witness on March 31, 2011. I certify that this 

memorandum contains all pertinent matter discussed with the witness on March 31, 20 II 

Kedric L. Payne 

Investigative Counsel 

MOl - Page 3 of3 OFFICE OF CONGRESSIONAL ETHICS 

207

EXHIBIT 14 

209

T ALDF Requests Criminal Investigation in Ohio Page 1 of2 

HOME 

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TALDF REQUESTS CRIMINAL INVESTIGATION IN OHIO 

ARMENIAN AMERICAN VERBAL THUGGERY PROVOKES CRIMINAL 

INVESTIGATION REQUEST 

Washington DC, November 3, 2008 - The Turkish American Legal Defense Fund today requested 

the Attorney General of Ohio, Nancy H. Rogers, to open a criminal investigation under Ohio law 

into signature Armenian verbal thuggery employed by Armenian American independent candidate 

David Krikorian against Representative Jean Schmidt. The Congresswoman represents the 2nd 

district of Ohio, and is running for re-election. The criminal lies under that Krikorian recently 

splattered against Ms. Schmidt are emblematic of the religiously and ethnically bigoted campaign 

tactics that Armenian Americans celebrate, directly or indirectly, against congressional candidates 

who refuse to salute their narrow, close-minded, fanatical anti-Turkish agenda. Ohio's Revised 

Code makes criminal intentional falsehoods calculated to impact elections. Other candidates for 

Congress who have been similarly victimized by Armenian American verbal thuggery in the 2008 

election cycle include Steve Cohen (Tenn.), Virginia Foxx (N.C.), Charles Hahn (Calif.), Robert 

Wexler (Fla.), and Jill Morgenthaler (III.). 

Kirkorian's criminal lies about the Congresswoman and her campaign supporters are posted on 

the Internet at krikorianforcongress.com. The Armenian American's posting in substance 

falsely accuses Congresswoman Schmidt of bribery and Turkish Americans who have made 

campaign contributions for her of paying bribes, i.e., that she bargained for campaign 

contributions from Turkish Americans in exchange for a promise to take official actions in 

Congress in opposition to perennial "Armenian genocide" resolution in the House of 

Representatives: "Representative Jean Schmidt has taken $30,000 in blood money to 

deny the genocide of Christian Armenians by Muslim Turks." 

Contrary to the Krikorian's lies, there was no quid pro quo or any irregularity whatsoever in the 

campaign contributions for Congresswoman Schmidt. As is customary in political campaigns, 

contributors make financial contributions to candidates who support the policy positions of which 

they approve. In fact, Armenian Americans and their political action committees scrupulously 

confine their contributions to candidates who support or pledge to support "Armenian genocide" 

resolutions. 

Congresswoman Schmidt's opposition to the Armenian genocide resolution is readily explained by 

historical facts. Her conclusions accord with renowned Middle East scholar Bernard Lewis of 

Princeton University, who has been consulted by the White House under President George W. 

Bush, and others of comparable academic prestige. The Congresswoman, based on her 

independent research does not believe the tragic events of World War I, in which both Armenians 

and Turks were killed in harrowing numbers, constituted genocide-an accusation that has never 

been proven in a court of law. She further maintains that the historical question is not appropriate 

for Congress to legislate. 

The Turkish American Legal Defense Fund has written a letter to Attorney General Rogers urging 

a criminal investigation and prosecution of David Krikorian under Ohio campaign and false 

statement laws, Ohio Revised Code, section 3517.02 and section 2921.13(A)(2), respectively. To 

paraphrase attorney Joseph Welch's rebuke to Communist witch hunting Senator Joe McCarthy, 

have Armenian Americans no sense of decency, at long last? Have they left no sense of decency? 

http://www.taldforglohio.html 
210

T ALDF Requests Criminal Investigation in Ohio Page 2 of2 

TALDF will oppose any assault from any Quarter on the right of Turkish Americans to participate 

fully in the American political process, including voicing their opinions on issues impacting Turkish 

-American relations or otherwise. 

Home I Your Rights I Issues & Cases I Comments I Contact I Links 

Turkish American Legal Defense Fund - TALDF 

1025 Connecticut Avenue; Suite 1000, NW Washington, DC 20036 

Phone: 202-370- , Fax: 202-370-1398 

http://www.taldforglohio.html 
211

EXHIBIT 15 

213

CtQ)~:u;:O . .Iw9[ -<>03 

SEFORE mE OHIO ill F.KIIIOn, A 

J~. " Sdlmidl 

5c: midt 1M eonv ... FlECEIVED $280 Mo"lgom~rvRd .. St~ . 21}11 

o,,~i Mri. OH 45236 APR 1 9 z009 

.. 

Mr. Oavld krikorlan 

CQMPlAlUT 

I, , .. " Schmidt, file till> Compl.lnt under Ohio R""ised CO<kI Sec!kon 3SH.153 and r Ih~ 

ro~lowfn~ under oath: 

I) I h .... ~ ,.pr~.<enlcd the Stcond Conu=ionar Di.Mct 01 ()I,i<> in Ih" United SUte~ 

CO!1gre ... i..a Jon"o'Y 2007. 

21 I <.mp~lu>ed fQ< r~ cle<lion In 2008. 

3) David Xnkodi n. '"''''''8 M on Independe"l, ,,,.is onc of my <>wonent5 In the gener.1 

cle<tion h.ld On ~ml>er 4. 1008. 

~) E~(h 01 the I.r,e :<Ia~m~l, e"."n~r>t d below we •• <I~"{:l1ed to psomotc hi. 

candld.'Y fur Con~ .. and 10 dcleot nw fth~«Uon bid. 

S) I hove ""Yilt r .... lved. don,:;"n In o,de,"'o Den\,thec",,,,;,Jeof (hd,Uo" Ar1I1cnl~1 

bv Muslim r,,,b,' I h_ ""_.r accepted ""y1hlnsof liaJt,e", ,. Iu,n for bcin, inUucnce<l 

1n the 11",1",,,1""''' <>I .... off",;.,1 MI (indudl<tllllonkln), whkh would be ~ fed.ral trim<! 

und...- 18 U.S.C.l:Ol. 

6) On hi • .lOO8 amp~lgn webslt" l~jt Q.!l."""w'~'"'~""<.!>fl£'u!.;<;"'b'i'9!:np!'ll ) 

Mr. I(ri , oti"," a<ser1~>tl : R~pr ... ~nt.ltlw lUll Sd1mldt II", Taken $lOJIOO In 8iood 

Mol\tV to o..IlY the Genoclde<l! Chri'ti~" A,,,,,,,,,,,,,, by Muslim Turb ." t:xhlbit I . 

7) Mr. Kril<o'I'~' . ,taten"!"t qllOled h\ p.r&Jlr:l~h 6 . bo,"" wa.ln ntlOl,.ltv f.,,~'Y ,lated 

I",,, in . t I.~" two re'pt'f.t. '" vkll>l!<ln 01 Ohio Rel'l«!d Code Sect;., ~ 3517 11(A)flO). 

OKSub_OO24 

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8) I have never "denied" an ArmenIan genocide. My position as a Memberof Congress has 

consistently been that the subject is not a fit question for Congress; and, that based on 

my knowledge of the historical record I cannot, at present, characterize the tragic 

events of 1915 in World War I as an Armenian "genocfdc .... ' whlth has a very strict 

meaning. As a Member of Congress, I have never voted on an Armenian genodde 

resolution. I support the formation of an international independent commission of 

exp-erts to resolve the rnJtt~r definitively. 

9) Mr, Krikorian's campaign website undermines his own false atcusation. The website 

recounts a statement in my office on March 29, 2007, which does not deny genocitle( 

but expresses agnosticism: "At thls time [Jean Schmidt] docs not have enough 

information to characteri7f~ these deaths as genocide especially when those responsible 

are long dead.'1 The website also quotes from a statement made in my office on May 11, 

7..007, in which I do not deny genocide! but make a different point about the exacting 

standards of proof COw15E!ing hesitation bdorf' leaping to a conclusion: liThe United 

Nations describes genocide 35 carryJng out acts: intended to Idestroy; in whole or in part, 

a natinnat, ethnic, racial, or I'eligious group,~ In thls instance, it was very difficult to know 

intent." 

10) On November 2~ 2008, Mr, Krikorian addressed a letter tOI "'My SlJpporters and the 

People of the Second COHBf€SS!onaf otstrict." It contains several knowingly false 

statements of fact in yiolation of Ohio Re"ised Code Sectioll 3517.21{A){1O). Exhibit 2. 

ll) Paragrapil 2 of the letter asserts: "I demand [Jean Schmidt's] immediate withdrawal 

from this race and her apology to lhe people <of the United States of America for the 

crime she has committed against our American soldiers and humanity by denying the 

undisputed facts of the Armenian Genocide." 

12) As elaborated in paragraphs 8 and 9 of this Complaint, J have not 'tdenied" the Arrnenbn 

Genoddu. (In addition, the "facts" are not '/tmdisputed:' Reputable American scholars 

who que'~tlon the appropri8teO;?')S of the genodde label for the- tragic events of 1915-

1916 include famed Middle [ast expert Bernard lewis of Princeton Universfty, the tate 

Stanford Shaw of U.CI..A, Justin McCarthy of the University of loulsvllle. Guenter tewy 

of the UnlversiW of M.a.$SJd~lj5etts> Norman Itlkowitz of Princeton University. Brian G. 

Williams of the University of Massachusettsl David Fromkin of Boston Univers;ty', 

Avigdor levy of Brandeis Univf.'rsity, Mit:hael M, Gunter O'f Tenne5~;e€ Techl Pierre 

Ob(~rljng of Hunter Co riege, the late Roderic DavisDn of George Washington Urlivet"~jtYl 

Michael Radu (If foreign Pulicy Research Institutel and mHltiJry historian Edward J. 

Erkkson. Outside of the Uf1ited States YE't mOff.' 5<:horars have- endOrSl?d a (ontrrJgenocide analysis of the history of tho Ottomon Armenians, amollg them Gilles 

Veinste10 of the College dE' Franre, Stefano Tdnches€! of the University of Chletf, 

i\ugusto SirHlgrd of the University of ROnl.ae·5ilpiem:a, Norrnan Ston,e of Bilkent 

Univet5ity, and the hist(Iriat) .Andrews Mango of the University of London}, 

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13) Paragraph 3 of the November 2, 2008 leIter repeats the false asseltlon that Jean 

Schmidt "deni[esr the Armenian Genocide. 

H) ParRgraph 4 of the November 2, 2008 letter further repeat. the false Essertinn that Jean 

Schmidt insanely "deni[esj".the Christian Annenlan Genocide at the hands of the 

Muslim Ottoman Empire." It also largely repeats the doubly-false statement in 

Krikoriants website for the reasons: ~et forth in paragraphs 8 and 9 of this Complaint: 

"Jean Schmidt has taken $30,000 in blood money from Turkish sponsored political 

action committees to deny the slaughter of 1.5 million Armenian men, women, and 

children by the ottoman Turkish Government during World War I: In addition, the 

statement makes the false assertion that J received campaign contributions from 

"Turkish government spon~ored'" poltUc81 action comrnrttees. No political action 

r-nmmit1f':~ that dOI1~t(?-d to my ("arnp3ign was srrurklsh government ~ponsored,fI True 

copies oftne affidavits of Uncoln McCurdy and Demir Karsanl Treasurer and President of 

Turki:,;h Coajition USA PAC and Turkish American Heritage PAC, respectively, are 

"ttathed as Exhibit 3. 

1.5) Paragraph 7 of the November 2, 200S letter again falsely accuses me of "den[yingj" the 

"'Armenian genocide" for tile reasons set forth in paragraphs 8 and 9 of this Complaint. 

16) Paragraph 10 of the November 2, 2008 letter falsely asserts: "Jean Schmidt has taken 

$30,000 in blood money from Turkis.h government sponsored political action 

committees and Turkish people in 2008 in exchanGe for helping them to cover-up the 

mass mtJrderof 1.5 million Christialls. This information is public record and can be found 

on the Federal F.lection Commission databa$€ at b1tQjlb~';I'.w.FE_(,gQy." Exhibit 4. 

17) '\5 set forth in parograph 5 of this Complaint, I have never accepted a political 

contribution in return (or being influenced In the performance of an offiCial ~ct 

(including inaction). 

J8} As set forth in paragraph 14, ! did not receive any campaign contributions from politi.c;;d 

action committees "sponsored" by the Turki:c;h government. 

19) The w:.:b:;ite .t:..t~,!y:-:yJ:.f.~D:ggy doe:). not suh~tantiate that politkal attion committees 

that !nude contributions to me were ,=,poosored by the Turkish government; nor does it 

identify campaign donor5 by ancestry. In other word5, thE web51te does not corroborate 

that I/Turklsh peopl(/' mC1de donations tD my 200S c;Qngre.ssiona! c;ampaign. 

20jlt Wllldd be ~ crime under federal law for the Turkish government (or any foreign 

national} to fund a politicol action committee thdt made donations to {) federal 

candidate seekIng election to Congress, :)!nong other federal offices. 2 U.S.c. 437 g{d)~ 

441 •. 

21) It wOillcl be a crime under fe-derallaw for NTurkish p.eoplr:(' to make contribution5 to 

federal political campaigns for Congn .. '!S5 1 ilrnong other federal offices, jf the donor were 

not an American cltlz€n or permanent n~:.;jdcnt <:lfien, 2. V.S .. C 437 g{d); 44] e(b}, 

DKSub_0026 

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22) Paragraph 14 of the November 2, 2003 letter repeats the false accusation that .lean 

Schmidt has "deni[edY' the Arrnenlan gcnQdde for the reasons set forlh in paragraphs: 8 

Bnd 9 of this Campi,,;n!. Exhibit 2. 

23}1 debated Mr. Krikorian on three occasions during the 2008 campaign. In none of those 

debates did he assert that I had solicited or received $30,000 from Turkish Americans, 

Turkish peopfe, or Turki5h political action committees for being Influenced in the 

performance of my official duties as a Member of Congress regarding: Armenian 

genocide resolutions, 

24) I have SpOKen to Mr. Krikorian face··to- face on 1 occasion in my congre'lsionaf office. In 

that meeting he did not i.lcc.use me of r€"ceiYlng campaign contributions in return for 

being Influenced !n the performance of my official dUties as a Member of Congress. 

25} Neither Mr. Krikorian nor his agents ever inquired of me, my 5taff~ or my campaign 

comm~ttee as to whether t had made any promises or commitments to being influenced 

tn the performance of my official duties about the Armenian genocide f(~501LJtian 111 

return for campaign contributions from "Turkish peop[eN or ''Turkish government 

sponsored politic:aJ action committeE's," 

26} In Mr. Krlkorian\: email exchanges with Ben LaRocco of my staff,it ",ras reiated to him 

that my knowfedge of the facts and the currently available evidente had not convinced 

me of the Armenian genocide claim. Exhibit 5. 

Wherefore, Jean Schmidt for Congress requests th6t the Commission conduct a nearing 1md 

issue a finding that David Krikorian violilted Ohio Revised Code Section .JS17.21(A){lO) 

during the 2008 general election campaign in the Second Congressional District of Ohio by 

knowingly making false statements of fact as set forth in this Comp!Jfnt, to issue a public 

reprjmand, and to grant such other rE'lier that th~ Corn mission flnd Just and equitable in the 

circumstances. 

Further affbnt sa'reth not. 

DKSub_0027 

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EXHIBIT 16 

219

IN TlIE OHIO EUC"IONS COMM SSION 

JEAN sc rr 

Schmidt fOf C""gre$I 

8280 Monlgotn.')' Ro:>d, Suite 204 

Cindnroti.OIOO 45236 

•.. 

COMrLA!NT 

Jean Scilulidl, being firs! duly !<Wom. <kPQSO$ fU1d M)'1 1U follOW!: 

\ . I MV. 'CP'=<llcd tile &,wnd Coogr=lONl 0;.1n01 ofOI,io in the Unitod Slat"" 

2. I .....,.. • candida1c: f« ~lectlon in 2008. 

KnkOfia" <lr>tkd >tid diwmi",tcd tbc let"', attached bC!c1Q .. r~ibit A. 

ond by promoting the ele<:lioD of aoother c:mdidale. 

"I ..;; tho pc<>ple of O!rio" ..,..""J e<>ngressian:ol <Ii.mel \Q &>k 

11,,,,,,,,,,1>",,", if our RCl',_"wivt .bould be laking lIlOIlOy from. 

fureign 8''''<:rcmc:n1 thaI i. kiUing 00' ooIilicP' 

RECfM.D 

JUl 2 1 2003 

OHKl ELfCTIQNS COI.II,IISSl0I1 

OKSub_0046 

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7. The above q!lofed statement is not the only falsehood contained in the attached 

E,lribit Ao Other 13loo statements in the attached E;cluui! A, "'C the subject of pending Ohio 

Elections Commissim Case No. 2009E-003. 

8. The above quoted sentence falrely accuses m<\ Jean Sdnnidt, of «bking money 

from a foreign government that is .killing OUT soldlenr. TIle cDntext is cll.:~n·. 

9. The above quoted statement is fatse. 

10. David Krikorian (~ither knows that the above. quutcl ~taleml;~llt is. rd~t:: ur has nu.de 

this fa]oe statement with reckless disregard of its truth or falsity. 

11, Moreover, the sent.ence immediately follo-wing the above qUDkrl stakment states 

that HIlle linked flyer is bdng widely dis1ributed acro~s tbe ~,ocond disirict in the last days of Ihls. 

C'.flD1paif::?1 season to expose Jean Schmidt as a betrayer of American hjRtOfY and her Chdstian 

lilith." The linke,! fly", to which Exhibit A refem 13 aU"chod hereto as Exhibit B. TbM, 1110 

recipients of Exhibit A will understand thal Jean Schmidt has taken $30,000 in hlood money 

from a foreign gO'lt.TImI(""Ilt that is killing oW" soldier.;. 

10. Neither 1 nor my Campaign Cornmitkc have ever '\ak(en] money from II foroi!:";1l 

gllvemmont", let along from "a foreign gove.rumcnt tint is killing our soldiers". 

11. It is" violation of R.C. :\5l7.2 1 (B)(l0) to: 

"Post~ puhU:->.h1 cllc\!latc, distribllU.\ or oth{.:rwtsc dissetninate a 

false s!atement coneerning a candidate, either knowing th(~ 3;;tme 

to be fahe or with Tecklc"s disre.gard of whetht..'T it was raise nr 

not, if the i)t:1tement .is de,:~lgned to promote the I;.~h)cti()u. 

nomination, or defeat oft.he candidate.'" 

12. David Krikori>.ll II,,, violated R.C. 3517.21(B)(JO} 

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WHEREFORE, Complainant mqucsts that Respondent bo found in violation ofKC. 

3517.21(B)(lO), and tbat he be appropriately sanctioned. 

l'urtherAffiants,'\yethnought. J () d '- J-j 

e'; 'I£~>fsJd&!f:i{Z{ ~-" 

..--- ~Jf/ Sworn to l)efore me and SUbSl11 rm my presenoo, thlsj'r {fay of July, 2009 

DKSub_0048 

11-6574_0182 

223

EXHIBIT 17 

225

Ohio Elections Commission 21 We:;t Broad Strcc~ Suite 600 

Coll.1mbu,<.;. Ohio 43215 

614-466,,-

::::;-;;:.::::::.--=::::::::::::.: .. ~)y'v..'W'S~:::.~}l:~~!eIc .,,~"":;:;=:::==:.:::.7'"..=::-~~-::.~~::::::::::=::::=:..-:::::~_~ 

lrnmR.Mroc;;o:k.Qwrld 

Vi~llllirmm 

Bryan feJmct 

Harvey H. ShaplHl 

LlltryWclp!';ft 

~~~~~~Of 

BRUCEFElN 

BRUCRFEIN & ASSOCIATES, INC 

) 025 CONNECTlCOT A VB. 

WASHINGTON, DC 20036 

November t3, 2009 

Ca~e No, 2.0091~003 

SCh..--nidf.,etRl.V" Krikorlr,n 

Pagel 00, . 

Plem;e he advised that o!), 101lt2(109 aftal"~reful cOl'lSidffiltion of [:-1(: 

evidence:,. the Ohio E1~t{Q~ Commi$ion adopted the following finding(s) in lht 

above refercnc<::d matter: 

THE COMMISSION ALLOWED THE fOLLOWING 

STATEMENTS TO BE WlTUDRA WN BY THE COMPLAINANT: 

1.) "Repr~;elltatiye jean Schmidt has taken $30;000 lIi blnQd 

money to deny the GenQdde ofChristi"l1 Al'll1Cnians by l..,.ill.qlim 

TUrks. 

2.) I demilnu her {Je:ln ')chmidt] irnrnedlatc withdr.D.wal-ti~)m t1ns 

race and her :lpology to til{: pwpleofthe United St;lt~ of 

America fDr the crime she h&~ comlIlil ted ugiliust our AmB[i<'.an 

soldiers and hum<:"lnily by denying the undis.pl.!k:fl f2.Gt~ nfthe 

ArmCt.-uan. Genocide. 

3.) ... JC<iJ1 Sclunidt's denial orthe Anne-num Genocidtl 

4.) .,' Jean Schmidt's insane dcrliaI of the C11ri:.."1:1il.l"l Armenian 

Genocide at the hands of the Muslim Ottoman Empin::.. 

6.) The f2CtS ofthe Armenian Genocide ;:lIe univm"R!lly fllX-epteJ 

by !1l1.ti-ons ru'01.I;Hl the WQlki, proBUlJ~nt s(Jholar3 find shtf~')mcn 

fmi.l ~O U S. ~tat(::s including Ohio. The oIlly denier:;! !)fthh gTC!lt 

tragedy which letl to the Holocaust ofthe J~V!:l by Nazi Gcr,mmy 

are the Turkish Governnient c;no certain rnc.mber ofthe Umted 

Stutes CcnW<'>'!;s including Jeilll Schmidt 

THE COMMISSlON FOUND ClO V!OLAT!OC! OF RC. 

§35I7.21(IJ)(1O) AS TO TUR FOLLOWING STATEMENT AS rr RELATES TO mE REl'1'4'l.ENC8 [N THIS STATEMEN r TO TIlE 

ASSFR nON THAT Wl\Jrkish poople g"e 130,000 TO kan Schmidt 

~nd or to Sc.hmidt fur CongreoSs. campujgll (mnrnittee"; 

8.) ThL" infu11!iH.tion is public f(':cord DJld om be finmd on the 

Fede,al FJec,tions Commissioa d;)tabll$~ at hn.n:j!":~:!Y}?l,r:.lli~;'M?_Y, 

(M lh;~ rut=".<l>ll rdC1'd">(:t.~ f3<1s \~M "~rlX--...-t tin ~(""le!\!"'< :lmt T\)rl;j~h l'"""'l>t~ ,'l,.q»tro SYJ,OCI) I 

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Case No. 2009E-003 

Schmidt, et aL v, KrikQIlHn 

Page 2 of3 

AN ADMINISTRATIVE DISMISSAL WAS DECLARED AS TO 

THE STATEMENT: 

7.) "J",m Scllmidt has t;,ken $30,000 in blood money fi'om 

Turkish government sponwred political action cornmntee.s and 

1Urkish people in 2008 in exchange for helping them to cover·up 

{he mnss murder of IS miHion Christians," 

THE COMMISSION FOUND A ViOLATION OF RC. 

§3517 .21(B)(1 0) BY CLEAR AND CONV1NCING EVIDENCE 

AS TO THE STATEMENT: 

5.) "Jean Scbmidt ha< taken $30,000 in blood money from Turkish 

government 1>lionsored political actiol1 oommit.te,~ to deny 'the 

sla.ughter ltf '.5 million Armenian men, worDen and children by the 

Ottoman Turkish Government Gllring W{Jrld \Var L" 

THE COMMISSION FOUND A VIOLATION OF R.C. 

§3517.2! (Bi( i 0) BY CLEAR AND CONVINCING EVIDENCE AS 

TO THE FOLLOWING STATEMENT AS IT RELATES TO THE 

REFERENCE IN THlS STATEMENT TO 'Hili ASSERTION THAT 

''Turkish govcmment sponsored politicai ~lction committees gave 

$30.0DO to Jean Schmidt cmd or to Sch.m~dt for Congress campaign 

corrul1ittcc": 

8_} Thjs infonnatkm is pt.;blia record and can he found Oil. tbe 

Federal EJ(>,dions Commission datahase at httj}.;!jYfYLYi.£h.C,gg.:{. 11l51111$ :>t~;e>\'lCII( ttim:l)CG [JI(..ts- !fl~t :f:!.Ij{lnrt ttlt ~1!lIIl'»-e!IIS\h:ilt·:-~fki~h &O'l'I;(\llIlfflf ~;:;(..;:,:J 

r~l1ti~1 ro;\ml oomrflineer, dlW~ll~ S:J{I,OO{lJ 

AS A PENALTY FOR THE VIOLATIONS FOUND BY THB 

COMMISSION 1N THIS CASE, THE COMMlSSfON 

DETERMlNED THAT THERE WAS GOOD CAUSE PRESENT 

NOT TO REFER THE MATTER FOR FURTHER PROSECUTiON 

BliT INSTEAD TO ISSUE A LFnER OF I'UBLIC REPRIMAND. 

if the decision in this cm;e inV(,lves the imposilion of a specific [we amount, 

;'J.H riot;. ,'md filing: requirements must be comp]:iro wi1h no later than 30 c~lY$ after the 

date oftbs tetter. Faym.e.n! should be made payablo lMd sent to th¢ Ohio lllectior.'s 

Con1rnLss.!cm <It the <lbnvt: address. 

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Ca,e No_ 2009E·003 

Schmidl, et at Vo Krikorian 

Page 3 of3 

If the disposition of this case involves a daily fIne amoUnlt you must cont;'Jet 

the office in which yon file yoor campaign fmance reports: and me the required 

report. In addition, you tml!4 flle a notarized staterntmt with. the Commission in 

order to have the daily fme lecotlSidered. 'The filings and affidavit ffiU.'>t be received 

within 30 w<ys: after the d1Ite ofthls Itl.ter. AU:properly notarized affidavits must 

include a st.nterneo.t above the notary public's signature that the document was sworn 

to andsubsc:ribed in the p!%ence of the n<ltary public and the date on which it was: 

done. 

If the decisilm h this case doe.') not involve the impositIon of a fine,. there is 

no furthC{ action reql.!ircd of)'tlu by the: Ctjmmis~ion. 

Htlle-decision in this case is ~r}-"'ersl! to ym~ tbj~ 'Case may he appealed 

pursuant to Ohio Revis.ed Code §119. A Notke of Appeal WILst be filed in J~ 

days. The Notit'E mUiit be filt'd with the Commission and a.Js.o at theCJedlls 

office for the Funldin County Court of Cnmmon "Pleas. 

In aU {'-3:~es, pk.a!le use the nEe Case No. 1isied at tile tap ()f!.hi~ lettcr ~hell 

(,'.on-esponding with Conunissicm. If you have any qut".stion, please feel !i'ec to 

contact the Commission .s:affilt (614) 466_ 

V{'lY trilly yours, 

Yhilip C. Rid.kr 

Staff AUomty 

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Ohiu EleeliliUs Commission 21 Wcoi Broad Street, Suite 600 

CQlumbu.<;,01)i043215 

614'466_ 

" ... 'f!:.yvw,~::.~~.~.~~~~!~. 

CharlesC'tlv~rt 

CNiruo.;;r< 

SolmftMrocl.tlwskl 

V~·ct~-")ml\ 

RqJ.l1 fdt:tO;1. 

Harvey H. Sb:il'Vho 

uuyWI'XPCrt 

J·hillpC,.Ri.dl~I:l.' 

.E.te~~Jlive Dfr~C%O'r 

BHUCEPEIN 

BRUCE FEIN & ASSOCIA7ES, INC 

1025 CONNECTICUf A VR 

WASHINGTON, DC 20036 

November i3, 2009-

Case No. 2009B-012 Schmidt, ei1l;L v. KrikOr-j;an 

Please be advised that ou.lOllI2009 after careful com:ideretion OfL1C 

evidence, the Ohio Elceti<J-l1ll Cou:nni~i(m sdopted til(: fblkrwiog- finding(s) in the 

eb<)vc referenced l1U\Ue-.r; 

TIm COMMISSION FOGND A ',~OLATION OF]tC. ,35J7,21(B)(lO) BY 

CLl3AR AND CONVINCING BVIDENCE AS TOTHB STATafENT; 

"l' flsk the pecple of Obio's Sl!'ctmd c(mg.t(;ui(mal district to 38:;0; thcm.sdv~ if 

our ReprtStl!liI,tiytl 311001cl be t.aking money fmm a foreign gQ\le.nWJent that 'is. 

kiUing om' soldiet'S"'" 

AS A PE1'fALTY FOR 11rE VlGLATION FOUND BY THE CO.f,.{1.USSiO}J fN 

THlS CASE, THE COMMISSION Dl"!-rf.l.{.\.m ... 'ED T'dAT THERE WAS GOOD 

CAUSE Pl<.E$f;}ff NOT TO REFFR TBB M\ 'ITER FOR rURTHER 

PKOSEC{rrrON BUT rNSTEAD TO JSSUl~ 1\ LE1TER OF PlJBIJC 

HEPRllvL<tND 

If the decis:on in lhis: C'l.~e inyolves the iD1pQsit.i.on ofu sJIff'.ific fine nmcl1l.jlt, 

Ell[ fine unci filir-.g requirements ImL.'1t be complied with no iat('.J' tban 30 days aftcr th~ 

date ofthi ... Jdter. Payment Mould be made payable &nil St'.:Jt to the Obio Elections 

Com...'1lis);i-on at the noove .lIdd(e:o" .. 

Trthe dlspo~itfon oft}j), ~~i!5~ ll.lY(..'·lYcs a daily tine aUl{)unt, you mu::>! '-'1Jr.:tatl 

tht:officc in wmcb you flI~ yOllr campaiWI fim:!l:lc-e ro,MU> !ind file th<:::f{)q:.lirt!d 

r~)Qtt, In lHldition, you must filen llOtari:?:t.".d stMmnellt with tbe r::o.!lll:aj!;~·i()n In 

-Drdm- ju navo the d<1i!y fiucrxonsid<".r-ed TI1t; filing;) imd affidavit mllst be rcc ...;.!'>·'tld 

within .30 days after tbe: (bill of ibis.' !etter. All properly TIOtariurl afIidavits nlUS! 

inr.:Judc a .';!(lier.u<!'nt above loe r:;OMty pubb<~>s signature 1h~t the oDclllfle:'nt was sworn 

to and subscribuf ii~ th.e prcsen,.evfthe notaryrmbHc anrllhe d<ltc on wb':':h i! was 

done. 

Utile dccisiOll in tNt ta"-i! dee~ TInt involve the irrtpositiOll of a fiDe, thcr~ is 

flO funhc.'f action requited ofyo!l by the Comt.!:!isJiit.,~~. 

If thl.< dedsio.n In tbh s:ns~ 1$ adwr~!? v) you.. [bbi Cil,se mny be lIppeai!!d . 

pUrsilMlt lu Ohio Ur;\,'ised Code §1 19. A Notke (If AptleaI must be filed !u Q 

dil}'~, The Notkc mu~t be flIed witb the (;ommis:lhHl find also at fhe ClIor}{ts 

office flrr the J'):rmldiu COMfY Court IJfCommQu l'te~$. 

In Bill cw.:es, P;C'-,-lSC m:e th<: OEC Care No. Usfed at t:Je fop I.'Ifthif.ldttt when 

ccnesponding wiU, CoounisswtJ_ if)'Ou have <lily qnesti<w, pie~se fc-d ftet': to 

~.O!l!"(;t tbe Cornmi!;sioD. ~t<lff at (614) 466.-

Very rrllly )ouJ's, 

Philip C. Rjchtr:~ 

(;fifi;}> ;:;f~ff AIl'4"I-.r~v 

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EXHIBIT 18 

.... .... 

a,b:! 

1.1>- 0° 

.... 0 

cof--' 

to 

1:12PM 

03110111 

AccrLJal Basis 

Typ-e 

Ordinary IncomeJExpense 

Bm 

8111 

Bill Bill Bill Bill Bill 

Bill 

Bin Bill Bill 

Bill Bill Bill 

Bill Bill 

8il1 

Sill 

Bill Bill 

SUI 

Bill 

Bill Bm 

8m 

Date Nom 

- ----

05/18/2009 051'27/2009 07129/2009 

09/21/2009 

091'2212009 

01f09/2009 03102/2009 

03.'11/2009 

03/19/2009 

08,'1712009 

08,0'1712009 

09102/2009 

11/0212009 

09/29/2010 1286 

11123/2010 1365 

03/0312010 1199 09,'29/2010 1286 

10,10612010 1295 

09l1J712010 Auto Debit 

09/1612010 Auto Debit 

09/20/2010 Auto Debit 

1110812010 AutoOebij 

11/0812010 Au;oDebit 11J0812010 AUloDcbit 

12/:3112010 Aula-Debit 

Turkish Coalition of America, Inc. 

January through December 2010 M

Bruce Fein ReimbuTSem€nt·BF 

Bruce Fein ReimbursemG-nt-Cabs-Colum

Bruce FeJn for ell! of Bruce Fein Rdmbursement for oul of pocBruce Fem Reimbursement for out af pocBruce Fein r.axi-Riembursement 

Southwest Airline AirpJane-Bruce Fein-Ohio Southwest Airline AirplancoBF·Ohio,Flight cha-n

3mce Fein Caes..OhiD 

Centinenla! Airlines Demir Karsan's Ticket for De:

Gc-ntin.ent;:ll Airlines Airplane Ticket 

Southwest Airlil'l6' Airplane-David Saltzman-Ohio 

Bruce Feit, Rdmbusemenl of out of pockBiUce Felli Airport transpmtalion Ginn TriBruce Fein Airport and meeting transport

Bruce Fem Assocmtes Inc. Meal Stipend lunch & Dinner 

8ruce Fein Meal Stipend Lunch &. Dfnn!;!f 

Bruce Fein Meal Stipend Lunch & Dinner 

United Airways Bruce Cinncinl'lati Schmidi v. 

E-xpedia Travel Bruce - Clnncinnati Schmidt cbpedla Travel Bruce - Cinncinnali Schmidt vDelta Airline Bruce flight - Minneapolis" CExpe·:lia Travel BrUCE - Cincinnati Hote! - SchExpedia Travel Travel Insurance - Bruce liS Airways Bruce Nov 2010 Cinncinnati S

233

EXHIBIT 19 

235

.' 

JEAN S(;HMIlYf 

Schmidt for Congreu 

INTIIJI: COlJRT OF COMMON rLEM, 

OJI CLERMONT (.'OUl\'TV, 0100 

82M Mon'Z(ltt\(:l)' Road, Suite 204 

Cincinnali, Ohio 4S236 

JUDGE HADDAD 

rJ.inliff, 

C_No. 2.£l/O cve J.J./7 

KRIKORIAN FOR CONG'Rr.ss 

e,uu' AIGN COMMITr,.; ..: 

21'M";nStreet 

Milfunl, 011. 45]50 

D<fer.d."Utl1. 

CO:'>IPLAIt(f 

;; 

.,~': 

''I~ 

'-~ :, :, ;: 

'":;{ . r. ~,. 

;:'- .;;( '" - - ~;·;i 

.G 

" d 

" ~ 

, 

-

~ 

~ 

.. 

.. , 

Plai"tiff Jean Schmidt hereby file.< her C<lmpLoint "f:'Iinst DefcndMtlI David K!ikDrian 

ond ,he Krikorian f~ , Congr= GIlmp<>it" commi ttee ."d oJltgcs ... follows: 

NAIU!lEQfn!lH;~1ia 

vf oottol'iicity in campaign fi!llml:e eri", .. , brlbo::ry. porjW)', Of oOslruCli"" of jnstice. They "i"~ 

fll,b1;.;.w ... ith in·will or <pile towards Plaintiff and wilh m.,,,1cdge uf !be;, falsity Or with 

pOlilk.,) ck:>n»in, which just;];"" a .tiff de:e"",t in I"tniHvt d"""'8"" to prev<Ill 'hrMic 

pi 

,-, 

(J 

OKSub_OO59 

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JURISDICTION AND VhNUE 

2, The conrt enjoys subject matter jurisdiction over t.hese tort actions under Rye. 

Chapter 2305.01. Venue is proper in Clermont County under Civil Rule 3(B){3) and (6) because 

it is where Defendants conducted activity which gave rise to Plaintiffs claims for relief or where 

all or part of the claims for relief 3rose. 

), Plaintiff, Jean Schmidt, was n political tmilblazor as the fIrst womfUl to represent 

southern Ohio in the U.S. HoU!;e of Represe1ltatives. She holds a B.A, in Political Science from 

lhe University of Cincilmati. Plaintiff Schmidt hes dedicated over 35 ye"rs to laDoring for the 

Clermont county Republk.(1n Party. Bef0re entering national politics, PJainHff served for eleven 

years ,)f, fl tnw!1c:.hip tmstee ,md for five years in the Oblo House of Representatives. She. has 

been a Member of Congress reprcsenti.ng the second district of. Ohio in the House of 

Rep,,'smtatives since she trillll1phed in a special election in 2005. Plaintiff Schmidt defeated 

Dcff.:ndant Krlkodan, then an im.lepemlenf, ill the: 2008 congr~sioIli! cIedion. She 1s a candidate 

again in 2010, svcking a fOl.:rth kIln in Cong:ress. She is a member of the Repuhlican Party 

4. Defendant. David Krikorlan~ is either the current or former rnanaging member Df 

Parody Productions, LLC, a Cinciunati based producer and distr'.hutor of novelty playing cards. 

In 2009, the Ohio Elections Commission voted to ruNkly reprimand Defendant Krikorian for 

malicious ihlsdl{lOds he pllb1ish~d about the Piainliff on the eve of the 2008 dectioH. He is a 

senior mm1ot..'r and former Chairrmm of the Armenian National Committee of Ohio! a local 

branch ofthe Armenian National Con:m,ittee of America (ANCA). It I::: the United Statf:l8 ann of 

the Amltnhm RevDh.ltlonary Fedcrfition~ a foreign political J)8Jty based in the Republic of 

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Armenia and which also holds s"ats in the national assembly of Lebanon. Krikorian currently 

,""rides at 8132 Camargowoods Ct.,.Cincinnati, Ohio 45243. 

5. During the Ohio Elections Commission hearings in 2009, Defendant David 

Krikorian acknowledged that he is respollSible for the actions of the campaign committee entitled 

"Krikorian for Congress," a Co-Defendant in this case. D1ll'ing Defendant's 2010 campaign, 

"Krikorian fur Congress" was headquartered at 215 Main Street, Milford, OH, 45150. Its 

treasurer is Nathan Bailey. Herdllafter, Defendimt David Krikorian and Krikorian for Congress 

shan be Ieferred to logether fiS "the Defendant.» 

BACKGROUND 

6. Most Americans "r Armenian ancestry take pride ill their heritage without 

disparaging those of othe.r national or ethnic hackgrounds. However, certain hate groups have 

tlsurped the terms "AmlCnh.n" and "Armenian Amt>rlc..an" in a way that is ullIepres(.ntative of the 

cbr..mctcr of most Americans of Annenian ancestry. 111esc self-styJed Armenian American 

leaders and organizations have u long history of accusing any person who declines: to endorse the. 

thesis that the ()ttoman Armenian tmgedy during \Vorld W~if I constitutes the crime of genodde 

Dfbt~ing a paid dupe of the Government of Tnrkey 0)" COll1plicit in the alleged genocide it:::e1f 

7. Most Arrnenlan. Americans do not intimidate~ harass. trllcatcn, 01 res.ort to 

violence against persons. organizations, or cOl.mliies: that dispute the Armenian genocide thesis. 

Nothing in this Complnint is inknded to walign or c~st aspcrsi·on on Armenian Americans as a 

group or to attribute to ih~m the conduct and character of the. hate groups and terrorist 

orgauiz.:'Hions that have chosen to label themselves (;'Arrr1e:nlall~~ or ~'An:ncnialJ American';. 

8, TVl/o prominent Armenian krrerist organizations) the Anncruan Secret Army for 

the Liberation of Armtnia ("ASALA'~) and the Justke Comma.ndos of the i'uT(J~Jrian Genocide 

DKSub_0061 

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("JCAG',), the fonner still extanl in Lebanon, were labeled by the I'm as the most dangerous 

terrorist organi7ations in the United States in the 19708 and 1980s, 'I1I.ey have corrunitted scores 

of terrorist act, on U.S. soil against Turkish officials, persons of Turkish descent, and persons 

whom they believed disputed their one-dlmensiona! understanding of Tmkish Armenian history. 

ASALA 0111 JCAG are responsible for 16 killings in North America, including five Tmkish 

diplomats:, one law enforcement officer) and ten civiIian:'i. Even U.C.L.A. Profe...c;.'mr Stanford 

Shawls home was firebombed in retaliation for his academic research on the issue, 

9. Other, Jess violent, hate groups and hate group adherents bave used dilTerent types 

of intimidation tactics to achieve their goals, Inc1miing ChaJ3cter assassination. 

lO. '111e first time Defendant Kriknrian met Plaintiff Schmidt was in Plaintiff's 

C01)gressional oft1ccs, prior to the: 2008 election cycle. Defendant Krikorian aemi.mrted that 

Plaintiff Schmidt beoome a CO~spOllsor 'of a resohltion condem.ning the government of Turkey 

and branding as «genocide" the \VaT crimes committed ill llie Ottormm Empire a century ago. 

When Plaintiff Scbmidt decline.d to llnmrdiatciy become a sponsor of such a resolution and said 

she that she would n(~d to study the issue first, Defendant Kriko.rian began sCh"-<lTIling at her~ 

calling her namC$, and thrcntening to ruin her pGliticnily. The interview ended soon thereafter. 

11. During tbe 2008 e!ectioll (,yd., Defendant Krikorian nm against Schmidt and 

Democratic nominee Victoria Wllishl~ as an Independent and as a sdf~stykd Reagan 

cons(Tvaljve. He pJi'lced t.hird in tbe contest. 

12. On the eYe of the 2008 geneml electiol1, Defend;l]lts publicly Jisscminutoo 

materii!.ls accusing Plaintiff Schmidt of being a paid dupe, which ~hc is nnL These campaign 

rnaterials faJse1y ac-cw,:ed Plaintiff Schrnidt of1uking money D:DIn the Turkish Gov(:rnment <l..t"Jd 

:frora 1\n::k.ish OOVt~nunt.~nt political actions committees to deny the Armenian holDcaust, and 

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falsely stated that this infonnalion wm a matter of public rceord on the Federal Electiom 

Commission"s website. 

13. PlaiI1tiff Schmidt bravoly held her grotmd and refused to be intimidated into <0-

sponsoring the anti-Turkey r<.solution despite Mr. Krikorian's threat, and despite her knowledge 

ofthe history of terrorism hy certaill selt~stylcd Armenian groups in the United States. 

14. In October 2009, the Ohio Elections Commission found that Defendant Krikorian 

had lied about Plaintiff Schmidt and ,()ted to issue lhree public reprimands to Defendant 

Krikorian for the malicious falsehoods that he published about Plaintiff Jean Schmidt on the eve 

of the 2008 e.Jection. 

15. Atler the 2008 election, Defendlmt Krikorian became a member of the 

Democratic. Party and entered the 2010 race for the scat held by Representative Schmidt. During 

his 2010 primary campaign, Def~nthUli Kl"ikorl,m was !"-:eus1Jred by state and local 10adc(,'j of his 

O'WIl party for making dis{Hlraging comments about the A~i::m-Tndian name of his opponent, Mr. 

YaJamanchili. On May 4,2010, Defendant Krikorian was defeated in the 2010 Democratic 

Primary by Surya Yalamallchili. 

16. In 2009, l'laintiif filed two eomplalnts against Oef"nd"u! David Krikorian before 

the Ohio EIf'A.',tions Commiss1on for severol counts of malicious false statement'> abcut PlaIntiff 

intended to in.tlucncc the outcome of the 2008 electiDn for the second congressional di~trict uf 

Ol1io m,der Ok" Revised Code 3517.2J(B)(10). On the eve of balloting in N(}vember 2008, 

Defendant distrihuted a flyer and an attached letter to vote:r~ in his dh:.ltict containing the 

following .~!aklTlcnis "'lith factual t.:onnotitio!!s: (a) Jean Schmidt has {aken $30,000 :in hlood 

mrmey from Tu.rk.ish govcmm.ent Bponsorcd political ndion committees to deny the slaughter of 

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L5 million Armenian men, women and children by the Ottoman Turkish Government during 

Wmld War I (Schmidt v, Krikorian, OEC 200%-003, 591-6(6); (b) This information (Turkish 

governm<nt sponsored political action committees gave $30,000 to Jean Schmidt or the Schmidt 

for Congress campaign committee) is public record and can be found on the FEC database at 

htWl/w·"w.FEC.gov (Schmidt v. Krikorian, OEC 2009E.003, 615··-628); and. (e) f a,k the 

people of Ohio's scwnd district to ask themselves if our RcprcSe.lltBtive should be taking money 

from. foreign government [Turkey] !bat is killing our soldiers (Schmidt v. Krikorian, OEC 

2009E-012,627-630), 

17. On October 1, 2009, The Ohio Electio". Commission mled that tbe three 

allegatioll$ referred to above were falsc according to dear and convincing evidence; and, that 

Defendant KrikDrirm cither knew they were fals(: or ucted with reckless disregard ofwh.ether they 

were false or not when he publjs~.d them (Schmidl v. Krikmian, OEC 2009E-003, 2009E-012, 

nOG) 627. 630). The Ohio Elections Commission detennined that lJefendant Krikorian had 

knmvlngly lied about Plaintiff Schmidt in his effort to defeat her in the t.~k:ctiOIl> ill violation of 

Ohio's elr.-ction laws. The Ohio Elections Commission voted to issue letters of reprimfmd to 

Defendant Krikorian for making these false statements of fact HS reflected in Exhibits I and 2 

attaohed hereto. 

18. Defendant Krjh~rian appeuled the Ohio Election Commh:sion's dedsion, The 

appeals were dis[("lissc',d, rnaking the OEC\; rulings final judgments, \vhkh trigger the docuin('"s 

of res judicata and collakral estoppeL 

19. 111C respective chairmen of tlJe DernOtTatic Party chapkrs in HB.miltrm. and 

Clermor~t countk's recently publicly condemned Deibndant KxikOJiaa)s patent radal or ethnic 

bigotry. According to' published reports, Krikorian pejoratively colTU"l1enkd <1bout SlJrya 

b 

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Yalamanchlli. his then opponent in the 2010 Democratic. Primary campulguj before a veterans 

group in Clermont County. He uttered wmds!Q ille effed that anyone with a name like that wa, 

uneleetable. The two chainnm reaeted with " letter characterizing the remark as "at best 

insensitive and at wornt ,., racist" They proclaimed thcir agreement with tlle views of 

Republican Party Plaintiff Sclh."idt: "[Wje have heard from severa! gourees that you have made 

f'Un of Surya YalrunanchiW.q name. Now) for once~ we find ourselves in agreement with the 

commeats of Jean Schmidt in the wmments she makes in the attached letter. Like YOll, Sury. 

]ws put great energy into his ca,npaign, and like ynti, he has won many friends along Ihe way, II 

is deeply disturbing to us that YOll would use his name, which is ohvio,dy derived from his 

ethnic heritage, again::ct him in a denigrating mamJC:f, especially given how strongly you value 

and celebraie your own heritage,)' 

20. Plaintiff Schm.idt earlier el~presscd her views on Defendant's sneering at 1\·ir, 

Yaiam(l..11chili's nmnc and anc.estry ill a xpMate letter to Defendant. She 'vvrote: t~The purpose of 

this Letter is to brlVe YOll fair warning that I will not stand by and allow you to nse racism to Smear 

your opponeni's nH111e as wa,s repurted tr.\ me by rhose attendlng a recent spce..ch yon gave, 1 wa.;;; 

rt'cently prcsenicd a report on a presentation you made to a veteran's group in Clermont Courrty< 

Yom remarks there \-vero offensive to an vvho ftnd even the hint of racism appalHng. During 

your presentation you ref('rred to your opponent rept;~teJly by dramatically and phonetically 

prnnouncing lUs narne, Poking fun at his heritage wa.s appalling enongh hut your nc:x1 comment 

was way over the line. YOl'; ,stflted> according to those 'vden:ms present .. (Now do yon reflHy thing 

a guy \-vith;\ name· like that has a chance at ever being elected?' Jl.,fr, Krikorfnn, I -do not t.hink that 

the residents of Ohio's Second Congressl(lnd District are mci~~ts, I am ShO(:KI?.!..j by your 

behavior. Futtber~ I wllI not allow your prejudice to go 1.11lanswered, You owe .Mr. YaJamanchili 

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and the Indian~American comm.unityan apolugy, Though I doubt that one is forthcoming gIven 

your history. Please conduct yourself in a man...lJcr fitting the office you seek. Racism has no 

place in the debate, period. Please be assured that I "ill conlinue to speak up about such conduct 

should it continuo. I know YOll are new to lbe Democratic l'mty but I would venture to guess that 

.such behavior \\il1 be particularly offensive." 

21. "''hen MSNBC's llbcral commentator Keith OlbermaIID named Defendant 

Kriknrbn <Ithe wor~t person ht the world~' for this behavior on April 30~ 2010, Defendant 

resorted to his soundtrack that hig detractors are invariably financially compromised. 

Yalc ..rnandrili had been employed as a brand manager at Procter & Gamble, Inc, Krik{)rl an bad 

seen an ad paid for by Procte" & Gambie, 111c. rlming Mr. Olbermmm's Countdown show. 

Defendant instantly charged: "Keith 01bermann is a buffoon for not .;.:hel:¥ing his sources, for 

not even bothering to cheek Bet l:ere's one thing I will state for the re.cor~J: La:st night's program 

was spon,ored by Procter & Gamble's Oil of Olay brand, wbich is the exact brmld tilat Surya 

Yt=l1amanchili ·worke.d for, So how did they cover that story la~~t night? Because I'm SUIe that 

Koit11 Olbennanll is not reading the Cincinnati press. So our folks think that tbe Ol) of Olay 

brand people - Procter and Gamble in particular .... Viere advancing their fllnn(~r employee, And 

thHt'S how it got in there. [ ... ] I think [OJbermann] was reading frnm his script. Su gI,Jmehowthat 

got put ill there. And how did it get put in there? Well, look ilt the relationship between the story 

nnd the snow" g sponsor. I thin1.:: irs lwctty dear how it got in tilCre."j 

22, ML Olben-nann rC$ponded: '''To flesh 1his out a bit: a) )10 advertise.r ~;5pon:-:;orsH 

1he show, We have commercials, hu1 b) I don't even ;see the ads on the show in the studio. We 

could be spo!lson,'·,d. by Crosley Radio and 1 \vouldn't knuw, And c) we chl?Gked which 

) lnt(~r'r'kw ;.vilh fohn WeHington Hrrnls on htlp:/lthbkpr:Ji;ress erg/201 O/05./03/hl?wri:.w.c()flspiracy/' 

8 

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evidently l\{r. Krikorian didn't know·· and we mn no Oil of 01ay ads on Friday; none from 

Procter & Gamble. A caveat: local cable operators do get a few minutes an hour to sel1. It's . 

pos;ible somewhere on Friday an Oil of Olay spot rdU during Countdown in a given city. But 

those "Pots usually go to smaller advertisers. and even 1flhoy don't, wo aren't told about them, 

would never know who they were, and get no money from them." He later added: "OK, now 

I'm told by an online viewer that P&G ads popped up before the show content on· line.'" 

23. Defendant Krikorian has publicly declared his passion to promote United Slates 

und international acceptancc of the thesis that "genocide of Christian Armenians by Muslim 

Turks" occurred in 1915. Defendant pcrcejve.~ any di!isenter from his view a~ a morally bankrupt 

enemy_ Each of the maliclmls defamatory false statements pubJi:;hed by Defendant ilbout 

Piaintiff and chronicled below were born ofthesc twin motivations. 

24. 'Tbe crimina! and defamatory <:Ic',;usa.tions fhat Defendant Krikorbn has serially 

leveled against Plahltiff Schmidt are part of a larger endeavQr to resmt to violence, accusations 

of crime] or intimidation against persons who chaIlcng-e any pl1Tt of their thesis. The endeavor is 

led in large measure by the Armenian Nutional Corrunitke of America ('~ AJ."\ICA"). Defenda:nt 

Krikorian has recently served a<.; the chairman (If the ANCA's Ohio hanch, where he remains a 

senior membe.r. 

25. ANCA~s apologia for Armeni<.l.n t(:rronsm under the banner of the GfJ10cidc thesis 

finds its high water mark in fonner ANCA Chaim·,an!vlourad Topalian. In 1999, the United 

States indicted Topn1i3n~ then an Ohio resident~ for termrist~1iDked hate crimes_ He allegedly 

possessed machin~ gtmS {lfld stcreu more tIlml 100 pDuuds of high expjo~iv('s ne.1ir a gasoline 

station adjacent tl) a day cam ct.nter in rk·dford} Ohio. Hls indictment connected him to four 

2 Available i3.t http:/ jdncfnn<l.t1.comjhiogs/politics/2010/G5jG3/krllwrl:mAY!amed.·worst-persm-:/ 

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terrorist attacks in the United States: lhe bombing of the Turkish Mission at the Unitod Nations 

Plaza OIl Dolak, 12, 1'180; the bombing at the Turkish Consulate in BeverJy Hills on November 

20, 1981; and, both the attempted bombing of the offices of the Honorary Turkish Consul 

Genem! in Philadelphia and his assassination on October 22, 1982.' Th. indictment also charged 

Topalian with training Armenla.n youths at a summer camp in the use of submachine guns and 

exploding booby !raps, ,ie.ling munitions, and dispatching individuals tt) Beirut for Imilling with 

international terrorist.:;:. 

26. After Topalian pled guilty to severn] of the above charges, including those related 

to the storage ofwcapons and unstable explosives in B(':dford) ANCA~Wes1cm RegiotllaureHcd 

him with a '~F.reedom Award" for his dedic3tion to advancing the Armenian Cause.1 At the 

September 24, 2000 banquet in his honor, the master of ceremonies declared, ··For r.}(lW thrm 

three decades, Momad Topalian has been Dne of {he t!w;::;t active, visible) and consistent pubtk 

advOc.a.tco;;- for the Armenian C&.n~;e. Against powclful opposition ,md at great p'..'IsoJJal 's:lcrif1cc, 

he has advanced tbe cause of liberty and justice for the Anuetuan nation and championed the 

increased involvement of Armenian Americans in the i\mericlln poEtical process." Some tell 

weeks later, the late U.S, District Judge Ann Aldrich, ND. Ohio, sentenced him to 37 rDDllths 

imprisonment. 

21, Defondant Krikorian bas tacitly defended or excused MOllrad Top<Jlhn by his 

failure to speak Cllt agaInst him, just as silence by Muslim leaders in the OnitE'd States after 

the attacks of 9/11 ... vould indicate acquiescence or endorsement of the terrorist 

abcmiIlat111n. Def~ndfiJlt Krikorian has never voiced disapproval of Iv10llmd Topalian or 0f 

:3 .Av8i]'1ble at 111.lpJLWJ..~V:t',\Hhnr.gi!.b .. @m.t.:J.!1.:J.gC1j~Jgilll.l,ngf. 

4- Avaibhle at t:tbJ>! iwww arf.iU'~lJ}';DgLis_hjAEr:N.t)}!d]Jm.{,l.L-l.QJPQ9.Jltrnl, 

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terrorism undertaken tn bring publicity or avenge the alle.ged historical grievance of the 

Armemal1 people. 

28. Defendant Krikorian ser,ed as chairman of ANCA's Ohio bronch until his entry 

into politics and remains a seniQr ANCA member. k'iCA publblw.rl an effusive statement of 

political support liJr Defendant on May 6, 2010. Among other things, ANCA's press ;oleas. 

stated: 

Armenian Americ~rn Cf'ngre.sslonal Candidakl David Krikorian - a 

staunch advocate of fIrst amendment speech and an outspoken 

opponent of genocide denial - garnered 38% of the Democratic 

pthnary vote in Ohio's second district - succumbing to baseless 

attacks by Republican incwnbent Rep. Jean Schmidt and 

Democratic opponentB, levied just days prior to the primary vote, 

reported the Armedan National Committee of America (ANCA) 

"David's COIlllr.d1nt(~nt to mnning a positive, grassroots campaign 

reflecitng the view!.> and values of Ohio's 2nd COllgres~ionJ11 

distrkt were mel with inclrmbcnt Armenian Genocide denier -

Rep_ Jean Schmidt'R false accu~:ltions and political scheming -

desjgned to knock ont her toughest Democ.mfic opponent from the 

Nove.mber general eiedions)" sa~d ANeA Eastern R{:gion 

Chairman, Steve Mc,srobi.m. "Loval Democratic Party teClders 

followed Schmidt's disll,formation compaign in lochiep and in the 

process did a grave disservice to OhIO 2nd di!:ririct voters." 

Rep. Schmidt, a perennial darling of the Turkjsh lobby for hor 

opposition to Congresslonal Iegislatkm ufflnning the Armenian 

Genocide, bas consistently tmgoted Krikorian most nonbly 

bringing charge, before the Ohio Election Commis.>ion in 2009 to 

(~over up references to Turkish American campaign contributkm::; 

ostensibly submitted in return .ttJ], her denial of the. }\.rHlcnifm 

Genocide ... ,'1i 

29. PlafntjlT SdUIlidt's prior c,-omplainls and the three public rcpnmands issm:d to 

DefeTl.ciant KrikMtP.ll by the Ohio Elcdlons Commission in the re~~olution of r;.ases OEe 2009E~ 

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003 and OEC 2009E-012 were insufficient to deler his implacable campaign of defamation 

against l'laffitiff. 

3U. On July 2,2009, Asbarez.coID, the onHne version of the Asbarez newsp21per~ the 

~elf-described official publication of the Armenian Revolutionary Peileration of the Western 

United Central Cmnmittee, puhlished an intc'fYiew with Defendant Krikorian in an m:ticle, 

entitJed, IIGeragos to Represent David Krikorian Against Genocide Denier.»6 The interviewer 

asked Defendant KrIkorian about his accusatiDns against Plaintiff St.Th.-rudt daring the 2008 

congressional campaign. Defendant Kribrian as,elied as [1Ct, among other things, ihal "8b,,~.~ 

3 L The statement, referenced in paragraph 30 assert or imply the following acts of 

moral tnrpitude or crimes that can 1)5 proven true or false: (a) that Plaintiff has hld(kn and 

continues- to hide the sources of her campaign flruding in vioJa1jnll of the Fed.eral Elections 

Campaign Act, 2 U,S.C. 434, 441e, 441£, 437g(d); (b) tlJ?t Plaintiff has knuwingly wlepkd 

money from a politicai action CUTI1l..uittt'-c funded by Turkish nationals in violatiDn of federal 

"O-'nl'aign finance laws, 2 U,S,c, 441o, 4411; 437g(d); and, (e) that Plaiutiffhas accepted brihes 

in the tcmn of c.nmpaign contributions from \Vall Street and Turkish interest PACs in exchange 

for offici"I act. in violation of 1& U,S,c, 201(h)(2). 

6 Available at httV! /"/"lW'N.<lsbre7.,corr. j66017/gcrsgos, roO' repre5enL·dilvid-kl'ikork1.n-agai.nst-g,mDcid e--

denier/. 

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32. The statements referenced in paragraph 30, individually and taken in the context 

of the entire intc";icw published by Asbare2.com on July 2, 2009, are defamatory becalLSe they 

falsely impute to the PlainHff corruption, deceit and the commission of criminal ,,[femes in a 

manner intended to min the reputation and esteem of Plaintiff professionally and personally. 

111ey wcre factual ""sertions published by Defendant with ill-will or spite towards Plnintifi; and 

with knowledge of tileir falsity or willi a reckless disregrud of whether they were false Or not 

33. During the interview publisbed on July 2, 2009, by Asbarez.com, Defendant 

34. By making the statement referenced in paragraph 33, Defendant Krikorian 

re.pubIished the factu,d assertions already deemed false and made with knowledge of their falsity 

Or wilh reckless disregard of whether they were false or not by the Ohio Elections Commission 

in 20G9 under Ohio Revised Code 3517.21 (B)(] 0). The OEC condudd that the following tln",e 

assertioru were publislwd by Defendant with knowledge of their hlsity or with a reckless 

disregard lor whether they were fahe or not by clear and convincing evidence; (a) kan Schmidt 

has taken $30,000 in blood money from Turkish goverument sponsored politic"! action 

committees to deny the slaughter of 1.5 miHion Armenian mctlj women and children by the 

Ottoman Turkish Government during World War I (Schmidt v. Kr'koJiol1, OEC 2009E-003, 591-

606); (b) TIus infurrruuion (Turkish government spons.ored pi)1iticaI action committees gave 

,~30.000 to Jc;<;n Schmidt <ifi(l/or to the SChiltidt for CongTess (;Hrllpaign committee) is public 

rccord and can be found on tho FEe database at http;!!v.'wvl.FEC.gov (Schmidt v. Krikorian, 

(lEC 2009E·003, 615 .. ·623); and, (e) 1 OSR the people ofOldo', secund "ollgK>siona] district 10 

ask thl!-mselves if OUT Representative should be taking mnr:.ey from a foreign govenuncnt-that is 

killing OUT soldiers (Schmidt v. Krikorian, OEe 2009E .. 012, 627 .. 630). Krik"rian's appeals of 

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the OEC's verdicts have heen dismissed, and the vccdicts .re now final and definitive 

ndjudications to be given collateral estoppel effect in this litigatiml regarding the falsity (If the 

statements and their publication ",itl! knowledge of their falsity or with reckless disregard of 

whether they were false or !lot. See Exhibits I and 2 attached hereto, 

35. The statement referenced in paragraph 33 is defmnatt)J"y becanse is accuses 

Plaintiff Sclunidt of violations of2 U.S.c. 434, 441., 44lf, 437g(J), 5 U.S.C. 7342(1,), and the 

Emoluments Clause of the United States Constitution, Atncle 1, section 9, cieuse 8. 

36. The allegations made by Defendant in 2008 were intended exclusively for voters 

in the second district of Ohio. The readership of Asoorez,wm, however, is not confined to 

resident") of a specific geographical location. By reiterating his three int.entionlli lie.) cbou! 

Plaintiff to the readers of Asbarez.com, DefefH.kuJ effectively republished them before the 

entirety of the Eng!ish-spe3king world.. Tl1e statement ref~:renced in paragraph 33 independently 

d~lIn3ged Plalritiif's reputation, and WB$. understood by 11s re.aders to incorpl)rate, among other 

things, the three intentional defamatory lies KIlkeria;) had made about Schmidt adjudicated by 

the OEC in 2009, 

37. During an August 27,2009 interview published by The .l\nnCn1im Reporter online 

news-paper in an article entitled "In congressional run, David Kr1koTian is banking on th.e people: 

Says he's 'ulldcrwhdmed' with Armenian-American 3Upport so far:'? Defendant Krikorian 

spoke out again .against Plaintiff Schmidt, making 1\-vo .more defhmatory itU{~gailons tbat can be 

proven true or false with knowledge of their talsity or with reckless disregard of wh('tncr they 

were tiusc 0'1 not and with iII,· will or f>pite tovvards Phtintiff. 

'"J k{ .. ibble at http://v.n.'lw.n:)Jorter.am/index..cfn:.?furl:::::/gO/3(tide /2009·09-! S· In- c(Jngres:::innal-:r.! !l-davidkrikonn n- is-banking· {In- the~peop)E.'&pg:;: 1. 

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38. Defendant Krikorian said: "What, I can't call nhe ... t\m<!§J~?jL.~~hpJilll .. wg;i.Y:fg 

)QQQy~.Just think how s.\!!JMl1!?! sound,." Defendant Krikorian also asserted as fact that: '\~1hil 

I1!llilsh goyenuncntj~ .. pchlnd those contributions an,ljtiSJ1)Yflght to feel that way aJ1.9,it is my 

39. The statements referencoo ill paragraph 38 are defamatory because they accuse 

Plaintiff Schmidt of dIe following net< of moral turpitude or crime: (al thal Plaintiff accepted 

c .. wlpaigll funding from the 'Ilrrkish government in criminal violation of2 V.S.c, 441e, 437g(d); 

{b) that Plaintiff has hidden and continues to conceal the source of crunpr:ign contributions in 

criminpJ violation of the Federal Electiom Campaign Act, 2 lI.S.C. 434, 44lf, 437g(d); (c.) ,bl 

Plaintiff is guilty of accepting money in exchange for an official act in criminal violation of 18 

USC. 2OJ(b)(2), and (d) that Plaintiff is guiltj of perjury \wder Ohio Revised Code section 

2921.11. 

40. '111C statements referenced ill paragraph 38 impute tn Plaintiff Schmidt corruption, 

fralld~ and the commission of (TL."11mai acls in a m:lImet intended to min thE! reputation and 

esteem of PJaintitT professionally and personally. They are factual assertions, published by 

Defend<iIJ:t with jJJ~v."iJI or spite towards l~laintiff and with knowledge of their t'llsity or vlith 

reckless disregard of whether they were fp.Jsc or not. 

41. In his interview with The Armenian Reporter publisk-d on Aug"'! 77, 2009, 

Defendant K.dkorian also asserted M fad that: '~~.:-' Schn1idLi~_J;ill}J.@.4t...~!lcL.naid for bv the 

15 

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42. In the statement referenced in paragraph 41, Defendant Krikorian accuses 

Plaintiff Sdmlidt of accepting money in exchange for official acts·in violation of 18 U.S.c. 

2Ul (b)(2). 

43. The statement referenced·in paragraph 41 is defe.matory becalLW it imputes to 

Plaintiff Schmidt comtption and the commission c)f criminal acts in a manner hltende.d to ruin 

the reputation and esteem of Plaintiff professioill\Uy and personally. It is a fi1ctua! assertion, 

publhhe<i with ill·will am! spite towards Plaintiff!ll1d with knowledge of iIB f.lsi!), or with 

reckles., disregard of whether it was false or not. 

44. An interview Witil Defendant Krikorian published by The Armenian Mirror· 

Spectator on Allgnst 28, 2009', contains two more defamatory sUl.kmentl. Defendant Krikorian 

asserted as fact, among other things) \yiih regard to Scf.:.ITlidt's deposi1ion under oath in the 

pending case of Schmidt v. KrikDrlan before the OEC, that t<~l:w~.cf.h!jDWJ Schmidt) sugQcstEx"! 

45. 'llle statements referenc.ed in p;ltagfilph 44 contain the assertion that can be 

proven true or false that P1Zlintiff Schrnidt ac.ce.pted bribes find iHegal ca...'11paign contrihutions 

ir{)m the Tmkish government in violation of 181J.S,C ).01(b)(2) and 2 U.S.c. 4410, 437g(d); 

16 

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and, that she commjtted perjury and obstruction of justice in her deposition in Schmidt Y. 

Krikorian ill violation of Ohlo Revised Code sections 2921.11 and 2921.32. 

46. The statemenl:!l referenced in paragraph 44 assert or imply the following acts of 

moral lU1pitude or crimes: Cal that Plaintiff has intentionally concealed the source of campaign 

contributions in c,imbal violation "f the Fc.de,"l Elections Campaign Act, 2 U.B.C. 434, 44If, 

437g(d); (b) that Plaintiff has accepted bribes, a criminal o.ffensc under 18 U.S.c. 201(bX2); (e) 

lbat Schmidt pcljuted herself and obstrueUod justice b her deposition in Schmidt v. Krikorian in 

violation of Ohio Revised Code sections 292Lll and 2921.32; and, Cd) that due to Plaintiffs 

alleged criminality, Plaintiff is a sharncnll human beillg unfit for public office. 

47. The statements referenced in paragreph 44 are defamatory because lbey impute to 

Plaintiff St::hmidt corruption, fr311d~ aJld the commission of criminal (lds ill ~ manner intended to 

nun the rormation and e,teem of Plaini'lif professionally and persor.ally. 1hoy are faotual 

assertions, published by Defendant with ill-will or spite towards Plaintiff and with knowledge of 

their falsity or a reckless disregard for whether they were fall'''' or not. 

48. In his interview with The Armenian l.,.firror-Spectator published on A1Jgll~1 28) 

49. Tl1e statement referenced in paragraph 48 a!:'.cu.~es PlaintitfSduuidt of perjury and 

obsmlction of justice as a puppet of the Turkish lobby in violation of Ohio RcvL~cd Cude 

sections 2921.11 and 2921.32. 

50. The statement rcf(~r''::llced in pardgraph 48 is defamatory be\..'-ause it imputes: to 

Plaintiff acts of deceit, col'nlption, and criminality. It is a f"el1le1 a%Crtioll made by Defendant 

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with ill-will or spite towards Plaintiff and with lmowledge of its falsity or a reckless disregard for 

whether it was true or false. 

51. In a televised interview with Annenian·Americ~'l activist Peter Mursulinn (a 

parthan journalist for Hmizon Armenian Television and Director of the ANeA-Western Region 

Board of Directors) in September of 20099

, Dofendanl Krikorian .. ,serted as fact, among olher 

things. the following: '1.§.!llnd by the statements that I made. that my onponent iltJJ:!f last 

the Turkish .. g9.Y."-ffim~nL.\r1yolved in Illeir denial campaign to suppress the trutll about ill!' 

Anncnian genocide.n 

52. The statement of fact that can be proven true or false referenced in paragraph 51 

is that Plaintiff receives money from the Government of Turkey in exchange for official acts 

regarding the perennial Annemaa g.cnocide resolutions introduced in the U.S. Congress. Th~ 

statement is defamatury b~caus.e it accuses Plaintiff of bribel'j1 in violation of 18 lJ,S.C. 

201(b)(2) and of UlcgrJ receipt of money from a foreign government in violation of the 

Emoluments Clause oft'w Constitution and 5 U.S.C:. 7342(h). 

53. The ,latcmen! referc'l1ced ill paragraph 51 was published by Defendant with ill· 

will ur spite towa:rds PlaintiIT <!TId with knowledge of its falsity or with reckless disregard of 

whether it was f<llse or not. 

54. The h&""1TI th3t the online pUblication of such a. permc10U0 ac.cusation can inflict 

upon the rep'.1tation of Plaintiff is both obvious and difficult to· overcomo. At prc,senL over 

11,000 vlewers have accessed this video on Youtube,co:n alone, The video is nearly impossible 

to rL"JIlove from circulation. 

" AvaHilbk at httv~ / /'wv/'.\!,yon lubf~,ccm /'YlJtch'?v"'I~n 7HhLV 4nlA&fcatll!'E:7rc1atcd, 

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55. Neithe.r Defendant Krikorian nor any member of Krikorian for Congress had ever 

inquired of Plaintiff Schmidt, her st.aff, or her campaign 'Committee a..<; to the truth .of Kirkorian's 

accusations of crbninality or otherwise. See paragraph 25 of the attached Exhibit 3. 

56. Plaintiff Schmidt has never "denied" that the Ottoman Armenian tragedy during 

World War I might eonstitute the CrinlC of genocide. Her position as a Member of Congress bas 

consistently been that the subject is not a fit question fur Congress; and, that based on her 

knowledge of the historical record she cannot, at present, cllli,ac.terize the tragic events of 1915 

in World War I as an Am1CIllan Hgenocide.~! which bas. a Yf..TY strict !ega! meaning under the 

Genocide COIlvention of 1948 and the U.S. ctiminal code, 18 U.S.C. 1091. As a member of 

Congress, she has never voted on a resolution calling these historical events genocide. She 

supports the formation of an intl'Tnational independent commission of expetts to re,'>olve the 

matte; definitively. See Exhibit 3, paragraph R~ Exhibit 4~ page 1. 

57. Plaintiff Schmidt h3$ never accepted anything of value in return for the 

perfor:rnance of lUI oflici,l act (or the choice not take an official action), which would be a 

federal crime under 18 U.S.C. 201 (b)(2). See Exhibit 4, paragraphs 5 & 14; Exlilbit 4, peges 1-3. 

58. It would be a crime under federal law for the Turkish government (or any foreign 

national) t() fund a politic-al action commiUe:~ that made donations to a federal candidate. saklng 

election to O:mgress, among other federal offices. 2 lJ.S.C. 437 g(d), 441e. 

59 It would be a (Time under fe.deral Jaw for Turki.sh people to make cuntributions to 

federal politic..'ll carn'paign~ for COllgre~:s, :":l!uong other feGer"l offices, jf tbe donor were not an 

American citizen or pcrma:nenl resident alien. 2 US.C. 437 g(d), 441c(b). 

60. The dt..~fa.'Vnatory .statements cnu.n1cti:ikd herein arc indh1dually and colle.ctively 

ruinous t{J P1aintiff professi()n3!1y~ JocalJy, nationally, 2..."l1d abroad. The-y have each proximately 

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caused Plaintiff general and special damages in the form of permanent and irreparable injury to 

her r~pntatiol1> 

61, As a direct and proximate result of the defamatory remarks poblished by 

Defendant Krikorian, many Ohio citizens were led to bell"". that Plaintiff Schmidt w«, guilty of 

njminally uccepting campaign contributions from a foreign goyernmcnt~ that she wa'i guilty of 

bribery, perjury and obstnlction of justice, and that her loyalty was to the Republic of Turkey in 

!lou oftbe United State" J:>JaintiffSchmidt's public image has been irreparably damaged 

62, As a direct and proximate result of the defamatory mnarb puhlished by 

Defendant refen'Ilccd in this complaint, Plaintiff Schmidt i, now disliked by many who feel as 

strongly about the genocide; interpretation of Ottoman Armenian history as does Defendant 

Klikoriml~ as 'wen n:- hy those who nQW believe thi.it 3he took money from instrumentalities oftlle 

Turkish govcnul.1cnt as H quid pro quo. DefcndanCs defamatory statements have proximately 

c.aused Plaintiff stress, emotional di5tress, and me.ntal pail1 and suffering. 

63, The statements refere.need herein ,tigmatize the Plaintiff as being guilty of crimes 

uf moral turpitude and disloyalty to the Unite.d States. They have diminished aud -...viU continue 

to diminish her oppmtunitic.$ to speak, to v:rite, to publish, to be inte.rvie\vcd, and to influence 

public opinioll 1111(1 ViC'\VS (lTI United States-Turkey relations and the history of Ott<JDlan 

Armenians. 

64. Defendants made the 5tntement5 referenced herein with fKtUlll malice and 

wmngfi11 a-oct willful intent tn h,,:.rm the PlailltifE The st8.tements were made with reckI ess 

disregard for their '..ruth or falsity or with knowledge of their falsity and with wanton and rcckle..'ls 

disregard of the reputation and right>;. of' the Plaintiff.. Defendants lae.ked Jea.sonabJe ground for 

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mal·dug the statements enumerated herein. Indeed, Defendants knew their statements were li~ 

when they made them. 

65. Plaintiff Schmidt i3 entitled to punitive damages in order to deter the use of 

intentionally fal,e criminal accusations against candidates to mislead the electorate and to inhibit 

or C0ufound full and fair debate about Ottoman Armenian history both in and out of Congress. 

The United State« Supreme Court elaborated on the evils of intentional Ues to the democratic 

process in Garrison v. Louis;ana, 379 U.S. 64, 75 (1964): 

Although honest utterance, even if inaccurate, may further the 

fruitful exercise of the right of free speech, it does not follow tbat 

the lie, knowingly and deliberately published ahout a public 

official, should enjoy a like immunity. At tho time the First 

Amendment was adopted, as today, there were those llnscrnpuJous 

enoug>.'l and skillful enough to usc the deliberate Or rcckkss 

£1-lst:hood tL<; an effective political tool to un;;eat the public servant 

or Iwen topple an adrninistrstiun. Cf Riesmatl, De.mocrac.y .and 

Defamation: Fair Game and Fair Comment 1, 42 Col. L. Rev. 1085) 

1088-1111 (J 942). TI,a! ,pooch is used nS a tool for political ends 

does not automatically bring it lmder the protective ma.'1tle. of the 

ConstitutioIl. For the nse of the known lie as a tool is at once at 

odds with the premises of democratic government and with the 

orderly manner .in which economic, social. or political change is to 

be "ffected. Calculated t"hehood falls into thnt class 0f utterunc,,-' 

which "are no e.ssential pmt of any exposition of ideas~ Bl1d are of 

sHch sHght social value ilS a siep to truth that <my benefit that may 

he derived from Illcm is dearly outweighed by the social inte.re.st ill 

order ilTIJ morality. , .. " Chaplinsl.y v. New Hampshire, 315 U.S. 

568,572 . 

66. Krikorian's irnjlenitence afkr receiving three reprimands from the OEC for 

inlentionu! lies about Plaintiff is transparent. He has uDsllccessfuHy brought suil in the United 

States District Cm!rt for the f;outhern District of Ohio sec.king a legal sanc.tu .. 'uy to continue to 

defhrnc Plaintiff with iutclltional Ecs. David Krikorian v. Ohio Elections Commission et al., 

Case No.1: 1O-~~v-00103. (attempting to argue th~t the First Amendment provides a bhL>J!cet 

immuni-::y for an speech during a politIcal ca.:-rrpaign), nmitive d81nages are imperative to deter 

21 

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Dofendant from continuing to harass, intimidate, and vex Plaintiff with knowing falsehoods to 

the detriment of Plailltif1; the democratic process and the Yoters of Ohio. 

67. Plaintiff incorporates by reference iuto 1his count the preceding aileh'Rllons ,,[this 

complaint. 

68. During the interview published Oll July 2, 2009, Defendant Krikorian asserled as 

69. It can be proven true or false whether PlaintiiT has hidden the SOurces of her 

C3!11paign -c.oniributions. Defend8.nfs statement accnses Plaintiff of criroirudity in violation of 

the Fedeml Elections Campoign Act, 2 U.S.C. 434, 441f, 437g(d). The statement was published 

with lU-wili Of :,pitc towards .Plaintiff ar:d with knowledge uf its falsity or with a reeklcss 

disrcgcmJ for whether it \vas fals~ ot not. 

70. 'TIle pt:blication of this statement caused general and special damages to the 

PJa!J1lilr. Defendants know. antid.pate.d, fore..o;;8.w) and intended that the statement would be: read 

by persons throughuut the United States and the world and Viotlld damage the reputation of the 

Plaintiff. l11c sla~ement has adversely affected the Plaintiff's professional credibilitY$ speaking, 

writing, interview, media) and fund-raising oppnrtllnities1 causing Plaintiff Schmidt 

psychological trauma and ~ufferjng and monetmy fosses. 

71. Plaintiff inc.orpol'ates by reference 1n10 this count the preceding allegation;.; of this 

complaint. 

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72. During the interview published Ull July 2, 2009, Defendant Krikorian ass"Crtcd as 

73. Defendant's statement accuses Plaintiff of knowingly BW:'1'ting money from a 

poli'ieal action commiltcc ftmdcd by Turkish nationals i11 violation of federal campaign [manee 

laws, 2 lJ.S.C. 4410(a)(I)(2); and, of accepting bribes in the form of campaign contributions 

from Wall Streel and Turkish interest PAC, in exchange for official ads in violation of 1& 

U.S.C.201(1))(2). 

74. This statemcnt was jJublished by Defendant with ill will or oopito towards Plaintiff 

and with knowledge of its falsity or with reckless di:;rega.rd for whether it w~s. false or not. 

75. The pnbbcatioll of this statement caused general ~md spcGiaJ damages to the 

Plaintiff. Defend3I1ts knew, anticipated) foresaw, and intendrd that the statement would be read 

by persons throughout the United States and the world and would damage the repnwtion of the 

Plaintif[ The statement has adversely affe.:;ted the l)l~intiff's professional credibility, speaking, 

writing; interview, media, and fund-raising GPporLunities~ r ... .'m~~ing Ptaintiff Schmidt 

psychological tralll1U'I: and ~mfferillg iilld monetary losses. 

76, Pil1~ntitfjncorpora.tc3 by reference into th1S count the preceding al1egaHous of this 

complaint. 

77. Du.ring the interview published on .T uly 2, 2009,. by A5ba.rez.t~OJn, Defendant 

23 

DKSub_0081 

11-6574_0213 
258

78. fly making this statement, DefendilIlt republished the factual osseliions already 

deemed false and made with knowledge of their falsity or with reckless diSTegm:d of whether 

they Were false or not by the Ohio Elections Commission in 2009 under Obio Revised Code 

35 J 7.21 (B)(IO). The OEC concluded that the fonowing three statements had factual 

connotations and were published by Defendant with knowledge of their talsity or with a reckless 

disre.gnrd for whether they were false or not by clear ilIld convincing evidence: (a) km Schmidt 

bas taken $30,000 ill blood money from Turkish government sponsored political action 

committees to deny the slaughter of 1.5 million Armenhm men, women and c.hildren by the 

Ottoman Turkish Government during World W& 1 (Sdmlidf v. Krikorian, OEe 2009E··003, 591· 

606); (b) Tills infonuation (Turki'h govcmmcnt sponsored political action committees gsve 

$30,000 t-u JCfUl Schmidt andJnr tn the ScP.Jn1dt for Congres~ carn.paign cDmmittee) is public 

record and can be [(mnd on lhe FEC database at hltp:iI"A'w.fEC.gov (Schmidt v. Kribrian, 

OEC 2009£>003,615623); and, (0) I ask the people of Ohio's second C<Jl1gHlssiOlWl dislrict to 

ask themselves if our Repres~n{ativt: should be taking money from a foreign. g()vernme.nt that is 

killing om soldiers (Schmidt v. Krikorian, OEe 2DO%·OI2, 627-{j30). See the attached Exhibit, 

.1 and 2. 

79. Krikorian'$ appeals of the OEC'g verdicts have been dismissed) and the verdicts 

are now final and definitive adjudications to be. given coliateral e-stoppe.l effect ]11 this litigation 

as to the falsity of Defe:ndn.nt's allegations and theiT publication vvith malice. 

80. T11C sidemcnt rckrcnccd in paragraph 77. in context, accuses Schmidt of t3.king 

money from a foreign gov(::T11ment in violHtion of 5 U.S,C, 7342(h) ond the £mIJ111mt:l.1l~ Clause 

of the U,S. C(mstitutloD) Artkle 1) sect.ion 9~ clause 8; of bTlbery in vioiation of 1 B U.s.C. 

201(b)(2); fll1d) of re(:eiviJlg illegal carnp:lign contributions in viOlation of 2 U.S,C. 441e, 

24 

DKSub_0082 

11-6574_0214 
259

437g(d), These accusations of crime against Plaintiff wero published with ill-will Or spite 

towards Plaintiff and with knowledge of their falsity or with reckless disregard of wbether they 

were false or not. 

81. 'Ihc pnblication of the statements caused general and special Jamages to the 

Plaintiff. Defendants knew, anticipated, fort.saw, and intended that the statements would 00 read 

by persous thronghout the United States and the world and would damage the reputation of the 

Plaintiff. 'The statements have advcrsdy affected the Plaintiff's professional credihHity, 

speaking) writing~ interview, media, and fimd-raisi.ng opportunities, causing Plaintiff Schmidt 

psychological tral.ffi1a a."d suffering and monetary losses. 

82. Plaintiff incorporates by rete.,enc(~ into this COlltrt the pn:'ceding allegations of this 

cOn1ptaint" 

83. During J.11 August 27, 2009 ini.erview published by The Arm~~nbn Repo11er in un 

article entilled "In congressional nm, David Krikorian ,. banking on the people: Says be's 

"lmdervir.c1mcd~ with AJ.menian"Arncrican ,support so far," Defendant Kxikorian made the 

following sL1tement with a deJ,rmatory factual assertion that could be proven true or false: 

25 

DKSub_0083 

11-6574_0215 
260

84. The statements referenced in paragraph 83 are defamatory becam,e they accuse 

Plaintiff Schmid! of the following acts of mumi turpitude or crime: (a) that Plaintiff accepted 

campaign funding from the Turkish government in crimina! violation of 2 USc, 441 c, 437g(d); 

(b) that Plaintiff ha<; hidden and continues to conceal the sourGe of c.ampaign contributions in 

criminal violation of the Federal Elections Campaign Act, 2 U.S.c. 434, 441f, 437g(d); and, (e) 

that Plaintiff!s guilty of accepting money in exchange f<O'r an official act in crlmi!121 violation of 

18 U.S.C. 2UJ(b)(2). 

85. The statements reterenced in paragr~pb 83 are defamatory becl1use they impute to 

Plaintiff Scbmjdt corruption, fraud, and the commission of comins} acts in a manner intended ~o 

nlin the reputation and esteem of PImntiff professionally and personally. They are faelual 

assertions, published with m~~"'ill or ~piic towards Plaintiff <lDd vYith knowledge of their fa.lsity or 

\vith reckks$ disregard of whet1~er ihey were faise or nni. Defc,ndant \VD.S pJaced on specitlc 

TIoiice that these statement.s were false dming the discovery processing eh one hearings heid to 

resolve ""ses 2009£-003 ;mJ 2009E-012. See Exhibit 4 atlached hereto. 

86. The publication of the statem~'llt3 caused general and spt,:dal damages ta the 

Plaintiff. Defendants knew, Ruticip&f<>d, foresaw, ad intended that the stalements would be read 

by person, throughout the United States and the world and would damage the reputation of the 

Plailltiff The statements have adversdy affected the Plaintiffs prokssional credibility, 

spc>aJdng, writing, interview) mccii::l:, c:md fond-raising oppnrflmitks, catl.Sing PhlilJtiIT Schmidt 

psyc:holop)cal trauma Hnd sllffc:dllg and monei.ary loSSES. 

87. Plair.tiff incorporatE's by reference inlo this eOUJlt the preceding allegations ofl1i$ 

complaint. 

26 

DKSub_0084 

11-6574_0216 
261

88. During an August 27,2009 interview published by Inc Armenian Reporter in un 

article; (''11titlcd "In congressional rUllj Dayjd Krikorian IS banking on the pCfiple: Says he's: 

~lmderwhehned' with Armenian-Arnerican suppOli so far,» Defe.ndant Krikorian asserted <L') fat-"1: 

89. Defendant Krikorian's statement aCCllses Plaintiff Schmidt ofecceptiug money in 

exchange for official acts in violation of 18 U.S.C. 20!(b)(2). It is defamatory because it 

jmputes to Plaintiff Sdunidt corruption PJld the comrnission of criminal acts in a tmUlller 

intended to ruin the reputation and esteem of 'Plaintiff proiesslon.ally and personaliy. The 

statement was pllblished with i1h'lill or spite towards Plaintiff, and with knowledge of their 

falsity or with reckless disregard of whether they ,veTe f:,dse or not, Defendant was placed on 

spedf1c notice that these statements \vere false during the discovery processing eh (JEC hearings 

held to resolve cases 2009E-003 and 2D(Y)F-012. See Exhibit 4 attached here.to, page;; 1-3. 

90. The publication of this statement callsed general and special damages to the 

Plaintiff. Defendants kncw~ antidpatcd, foresaw, and intended that the statement wDuld be· read 

by persons throughout the United States and the worM and would damage the reputation of the 

Plaintiff The statement has adv(~Tsely affc:ctcd the Plaintifr~ professional credibility, speaklng~ 

vniting, int{';n'lew~ media? and iWld~ndsing opportur:itics, c.ausing Plaintiff Schmidt 

psychological traruna and suffering and monet.ary losses. 

91. Plaintiffincorpomtes. by It'fcnmec into this count the preceding .al1t:.gath.ms Gfthis 

complault 

n 

DKSub_0085 

11-6574_0217 
262

92. In his August 28, 2009 intervicwwith The Armenian Mirror-Spectator, Defendant 

Krikorian asserted as fact, among other things, that "She's (Pl!!lJl1iffS"[1I1)J<;!1jflltji:g;..;ille's not 

district and to Jl!@~~9'lmhy~" 

93. The statement contains the assertioniliat can be proven true or tiil"" that Plaintiff 

8t:Junidt accepted bribes and illegal campaign contributions from the Turkish government in 

violation of 18 U.S.c. 201(b)(2) and 2 U.S.C. 4410, 417g(d), and that she committed perjury and 

obstruction of justice in her deposition in Schmidt v. Krikorian in violation of OhIo Revised 

Code sections 2921.11 and 2921.32. 

94, 111e statement referenced in paragraph 92 asserts or im.plies the following acts of 

moral rurpitllde or crimes: (a) !n;lt Plaintiff has Iutt;71tk·nally concealed ihc somce of campaign 

contributions in criminal violation of the Federal Elections Campaign Act, 2 U.S.C. 434, 441f, 

437g(d); (b) that Plaintiff has accepted bribes, a criminal offense under 18 U.S.C. 20!(b)(2J; (e) 

that Schmidt pf...'Ijurcd herself and obstructed justice in her deposition in Schmidt v. Krikorian in 

violation of Ohio Revised Code sections 2921.11 and 292J .32; and, (d) that dne to Plaintitrs 

alleged crinllnaIity) PlaintifIis a shameful human being unfit for pul)1ic offke. 

95. The stlteme.nt Iefcrenced in p:3.rugraph 86 is defamatory because it jmpntes to 

Plaintiff Schmidt corruption, frttnd~ and the cDmmfssion of criminal acts in a manne)' intended to 

ruin the reputation and esteem of Pbintiff profcssiomlUy a.nd personally. 'l1"l.ey are factual 

a.ssertions, published by DeIendant with m-\vill ()r spite towards Plaintiff imd \vith knowledge of 

their falsity or 11 reckless disregard felt whelher they were false or not. Defendant iVBS placed on 

28 

DKSub_0086 

11-6574_0218 
263

specific no1lce tbt1 these statements were f~lse during the discover! process in the OEC he-?..rings 

held to [e.solve cases 2{)09E-003 and 2009E-Ol2. See Exhibit 4 attached hereto, pages 1-3. 

96. The public8lion of this statement caused general mld special damages to the 

Plainliff Defendants knew, anticipated, foresaw, and intended that the statement would be read 

by perSOllS throughout the United States and tllc world and would damage the reputation of the 

Plaintiff The statement hilS adversely affected lhe Plaintiffs professional credibility, speaking, 

writing? interview, media., and fund-raising opportunitiesl cansing Plaintiff Schmidt 

psychological trauma and sulTering and monetary losses. 

COUNT-YJL::J)EFAMATION PER Sl.1 

97. Plaintiff incorporate", by reference into this count the preceding allegntions Qf this 

('.omp!31nt 

98. In hi..') August 2S. 2009 interview with '.TIle ArmenluH MiTIDr~Spe(:tator~ Defendant 

99. "Ihc statement is defamato!), because it accuses Plaintiff Schmidt of perjury and 

ob$truction of jm-=ticc in violation of Lh.e Ohio Reviscri Code sections 2921.11 and 1921.32 in a 

manner intended to ruin the rc..'Putation and este.em ofPlajntifIprofessionally and pel'sor;ally. 

100. The statement Vias pubJisted with ill· will or spite tGwnnis Plaintiff and with 

knowledge of its' falsity or with l'e<:kless disreg8.Td of whether it was f~ltoe or not. Defendant 

wus: placed on specific Dotice that thc~~e statements were false during the di')cQvery proces:,; in the 

OEe hcari<1gs hold to resolve caseg 2009E·003 and 20092-012. So", Exhibit 4 attached herete, 

page 5. 

29 

DKSub_OOB7 

11-6574_0219 
264

1OJ. The publimtion of tl,is sta!ement raused general and special damages to the 

Plaintiff. Defend?..nts knew~ anticipated, fore.~aw~ and 'intende.d that the statement would be read 

by persons th.roughout the United States and the world and would damage the reputation of the 

Plaintiff. The statement has adversely affected lhe Plaintiffs professional credibility, speaking, 

writing, interview, media, and f,md-raising oppOltunities, causing Plaintiff Schmidt 

psychologicai trauma and suffering and mOllcbry losses. 

102. Plaintiff incorporates by reference into this count the preceding allegations of this 

complaint. 

103. In an rr.lkrview with Anm.·Jllan~Arneriol11 activist Peter 11ursnllan in S<~pkmber 

mv opponent in the Ja.<.;t election. the ~mrent renresentative of Ohin's second copgre,ss1011aJ 

1 04. "111t~ state.nent uf fC'!d itmt can be prov(~n tme OJ' fBl':)t~ i.~ thOlt Plaintiff receives 

money from the Government of Turkey in exchange for o.fficial acts Tcgatdlng the perennial 

Armenian genocide resolutions introduced in the U.S. Congress, The statcrnent is dd;nn~tory 

rn,cause it accuses Plaintiff of bribery ill violation of 18 U.s.c. 201(b)(2) and ofil1egal receipt of 

money [Tom a fhreigll government in violation of the Emoluments Cbuse cfthe COl1:stih.ltion and 

5 iiXe. 7342(1). 

j 05. The statement was published by Defendant with ill-will or spile towards l'laintift 

and with knowledge of its falsity or with rcokloss disregard of whether it wag folse 'Or not. 

Defcndm:.t was placed on ~;pecific notk.e that th';.~se statements were f~t!se duril1g the diseoY~ry 

30 

DKSub_0088 

11-6574_0220 
265

process in the OEC hoarines held to resolve C:<lSeS 2009E-G03 and 2009E-012. See Exhibit 4 

attached hereto. 

WHEREFORE, Plaintiff demandsjl1dgment against the Defendants,jointly and severally, 

as follows: 

(a) Compensatory damages ill the amount of $500,000 on each Count; 

(b) Punitive damages in the amount ofS350,OOO on each COlm!; 

(c) Pre.judgment and post·judgment interest 01\ each Count; und, 

(d) Such other and further relier to which Plaintiff may be entitled. 

OF CmJNSllL FOR PLA1NfIFf: 

Bmce Fei" (DC Bar 446(15) 

1 025 Connecticut Ave" NW 

Suite 1000 

Email: ~1tbdicWic1dgrQup.com 

31 

Rc:)pcctnlily Sllbmitted, 

jl~(~ Donald C. Erey (0021965) 

CHESTER, WiLLCOX & SAXB LLP 

65 East Stale Sir",,!, Suite I COO 

Columbus, Ohio 432J5 

Tolophone: (6;4) 221 .• 

Facsimile: (014) 221"1012 

Email: _@cwslaw.com 

CO\.iIlSel for Plaintift Jean Schmidt 

DKSub_0089 

11-6574_0221 
266

David Saltzman (DC Bar 426201) 

655 15th SI. NW 

Snite225-F 

Washington, D,C, 20005-5701 

Office: 202-637 __ Mobile: ___ iii Facsimile: 202-637-9876 

Email: ~nrklaw.net 

DKSub_0090 

11-6574_0222 
267

EXHIBIT 20 

269

,---------_._--------------

DKSub_D217 

11-6574_0224 
270

DKSub_0218 

11-6574_0225 
271

DKSub_0219 

11-6574_0226 
272

l __ _ 

DKSub_0220 

11-6574_0227 
273

DKSub_0221 

11-6574_0228 
274

DKSub_0222 

11-6574_0229 
275

DKSub_0223 

11-6574_0230 
276

DKSub_0224 

11-6574_0231 
277

DKSub_0225 

11-6574_0232 
278

DKSub_0226 

11-6574_0233 
279

DKSub_D227 

11-6574_0234 
280

DKSub_0228 

11-6574_0235 
281

r 

I 

DKSub_0229 

11-6574_0236 
282

DKSub_0230 

11-6574_0237 
283

DKSub_0231 

11-6574_0238 
284

~------~----

DKSub_0232 

11-6574_0239 
285

DKSub_0233 

11-6574_0240 
286

DKSub_0234 

11-6574_0241 
287

DKSub_0235 

11-6574_0242 
288

DKSub_0236 

11-6574_0243 
289

DKSub_0237 

11-6574_0244 
290

DKSub_0238 

11-6574_0245 
291

DKSub_0239 

11-6574_0246 
292

DKSub_0240 

11-6574_0247 
293

DKSub_0241 

11-6574_0248 
294

---~-~-- ~ -~~--~-~-~--~~~~~~----~-~~ 

DKSub_0242 

11-6574_0249 
295

DKSub_0243 

11-6574_0250 
296

DKSub_0244 

11-6574_0251 
297

DKSub_0245 

11-6574_0252 
298

DKSub_0246 

11-6574_0253 
299

DKSub_0247 

11-6574_0254 
300

DKSub_0248 

11-6574_0255 
301

'." '!l C' 

~~ "; , 

DKSub_0249 

11-6574_0256 
302

DKSub_0250 

11-6574_0257 
303

DKSub_0251 

11-6574_0258 
304

DKSub_0252 

11-6574_0259 
305

DKSub_0253 

11-6574_0260 
306

DKSub_0254 

11-6574_0261 
307

DKSub_0255 

11-6574_0262 
308

DKSub_0256 

11-6574_0263 
309

DKSub_0257 

11-6574_0264 
310

DKSub_0258 

11-6574_0265 
311

DKSub_0259 

11-6574_0266 
312

DKSub_0260 

11-6574_0267 
313

• 

DKSub_0261 

11-6574_0268 

315

EXHIBIT 21 

317

\"/' iZ',/fi! t:;;~,:,;.· 

,.l:~d ;. ,~:'~ f.,)Y" In,,''A \.'t:ti 

Schmidt_0029 

11-6574_0270 
318

~;.,.~\:n\};dl.\n, 

lhiH1\' 

Schmidt_0030 

11-6574_0271 
319

EXHIBIT 22 

321

Thl..': Honorahk Jean Schmidt 

U.S. 1 louse of Representa1ives 

COl\i1\~!r:'[E UN STAf'oJD,4!':1[)S O~ 

OFFICiAL (,0:\lD0(;T 

:Rhgl;mgnH, t\:c 20S13-G328 

f'ebmary 26, 20!O 

238 Cannon House Office Bui\(lini 

\\/~''.l·,''-g;'m P("' 711t" 15 

Dear C () ncag lie: 

This rc!'ponds to YI..)UX letter \)( Scplember 17, 2009, se~king an aJvisory opinion regmding 

two options for paym~nt of legal (':'\pens~s inl..'\.un .. :-d in conm.'ctlon \I,.'ith a case you Jil.·xl in 2009 

rcgnrdillg fit.!se campaign statements.; As d~scussed hc1ow, the ('stablishmcnt of a legal exp~nsefund ;md the us.c of campaign hmds are both permissible Opti011S t0r payment of kgal c.xpc.nsl's 

in conncctlon I.,vith hoth paBl and future proLeeJings .. :-,uhjcd tn th>.: limitatinns bdO\-v. 

to your letter and udditl(Jnai informatiun pn)\'idc\l to Committee (:ounsel.. the 

background in mutter is as follows. In the final days of the 2u08 g~l1('ral dcction campaign. 

one of your opponents, David Krikorian. distrihuted materia!s al.:'.t:uslng Y0U of ;.K'Gepting a 

$30.000 hribe ii-om the Go"Crnmcnt or Turkey in exchange k'f denying nr cm(ring up the 

geJ1(lcide of Anncnians in Turkey during \Vodd \Var L 1"11(' campaign Jnakrials also '.:8.!led fiJI' 

}OLU" immediate fC'signation From your con~}esslonal seat and/or your ddb.ll £It the polb in the 

200R general election. You \vere fe-elected in th¢ 'November 2008 g('n~ral dl'('tion. 

In Aprlll009, you filed a s\\'orn cumpbint against Mr. Krikorian ,.,\ith the Ohio Elcdiuns 

C\)l1imission (Flection Commission): \'vhich has jurisdjctlnn o\cr false campaign slatC'll1(;nts 

under Ohip hl\V. S'ee Ohio Rey. Code § 3517.21. Based on the Election Commi~si0n':-, 

jurisdiction, ),Oll iilt.:d the complaint as a cJ.ndidatc with your carnpalgn cm1llnith::c address. That 

complaint ;.;ought (1) <l finding by the Ekcti{)ns Commission that \ir, Krikurian "</lobtcd § 

~517.~1 by making. t~)ls.: campuign Shucmt..:nts; (2) a public r~rrimHnd; and (3) oth>.!r 

appropriate rdieT On or about October !, 2009, yOU n:ceiv¢d a finding 01' tl:to;;t thl? 

C!cctiun::; Commission that there \.vas clem nnd con ..... incing evidence thn.t Mr Krikt)rian rnad< 

f~dst.· staT.cm~nts \viih In;;11iCC. 

l:nd~r Ohio !av,' .. you \\it.>l\' rcquir0d lO Hk nay chi! ],:!iOIl :"ecking 

(\mrt of ('ornm011 Pic-as {(Jilt0 ('<)urt) 1.10 latt.'r th,J.n [ln~ y,,'ar fron) the d;lk (,I' 

in Ihc Ohio 

\:; th"," 

Schmidt_0001 

11-6574_0273 
322

The 1 kmomhk 3mn Schmidt 

[)ag~ :2 

time pl!yi\)(l ltU:-i \.:xpirt;J, you \-\--ill no! he t'illng d -I.::i-vil action to l\"'cOVcr da111;.ig~·S in this matter, 

!-Ic'I\Y(:ver. rvir. Krikorj~m has iiltd an :lppeal 111 the Ohio C;)urt seeking to oveJ1urn th~ 

adrnlllislWl1ve ruling by th~ EIl;!dion Cornmisslun. 80th you and the Ohio AttOl'll':Y Get1.::ral arc 

named p~lni(;:'s in the nppcnl\ arH:l you \vill inl..~ur adclitiunal legal kes to participate in tho;...c 

prol.:('cciings, Finally, 1\11', Krikorian has .. 1150 likd a civil sult in ihkml (oun chalknging the 

constitutionality· of the Elections Commis~jon ruling. y~)U ;.u-e not a named party to this fedel'al 

cnurt L.r.lSC and Jo not anticipate any inrokl"m':llt in that st~parale litigation. 

You have not uSeJ your fIoul)~ st-aff or l,.·umpa.ign stall to support tbis Wigation. Barry 

Benn~tt. your ~hief of staff, l~ familiar \vith the case, hi.lt his official iu\'ol\'emcnt hQS b0cn 

!imit~d tu Honse G..:nc-ra1 C\lUJ1Sel \'I;ith r~gard to disC0\'0t; n:ql..l~5t responses, beiJlg 

deposed such discovery requests, and working \',:it11 the Committee to obtain 

guidance on the issues in your September 17. 2009~ l(.'t1~r. 

Your Jl10rncy in this matter has been Bruce Fein Oflhc Turkish American Legal Delel1Sc 

Fund t l'ALDF), You have not signed any retainer or representation agn:crncnt with .\:fr. J,\,~lll. 

but he did provide you \\"ith a proposed c(ll'Hingency re~ contract, !iecaust: ji,)l.1 arl;! not filing any 

civil nctkm to feCO'ver dam.ages. you v.,-ill not be entering into thG contingency t~e contracl \.',dth 

1\·1r. Fein. To dale, t-..1r. Fein estimates that 200 hours h,wc been \\-orked by the attorneys in yom 

(:t.lse. hut you h:;lve not yet. becn billed as ) ou are aV"aiting this Committee's guidance regan.ling 

1h.: permissibility of th:: propo~;('d options for payment of legal expc-ns0s in this matter. 

Accordbg to information in public database::.; and \Vcb sites, TAT ,DF is a prc~jcct of tht: 

Turki..;h Cllalitiun (If /\mCrlca (TCA), TCA is a § 501(C)(3) organization under the "Internal 

Re\'cnue C0de~ has employed registered fcdt.:'ral lobbyists under th0 Lobbying Disc:losUTc 

/\ct in the past. It appenl"s that fAI.DF issueu a press release and fequest f{)r a crimin>'lj 

investh1.<1ti()1) w}J1.jn~l Mr. Krikorian on N0v.:rnb-::l' 3) 200S-. re!d,arding til.; same allegations of "f[llse 

,-'ampnign st~H!;.\7ncnts that undc:r1ie your complaint \\'llh the f~i.:etion-" C0l11lnission,- Both T,-\LDF 

1nd TCA issued .')t~1tc'm~nts regarding the faYOfable l'uling in your l:asi..' on OI.-'tOht'f 2.2009, 

You seck Committee guidunce r(;garding t"vi/O options Cur p<1sing leg31 t'xp~nscs both fIJI' 

legal \\ork already c:omp!dcJ during the Elcctk1l1s Co!mllis~jon pro(:(·.-:dings, ;;mel future lcgi11 

W(g[,. ()H your behalf in tht~ .c-lppdlate case in the Ohio Court: 

1. Lstablis.bing.n Leg,tl Expcns~ Fund under I.he (\Hnmiuc~~'s rcgubti~)J1s~ \)1' 

"') "t"sing ctimpaign funds from ),OHf principal campnign commiHe'~. 

YOl! h<.nc !H..1l yet conlacted the FCl..kr.11 F!cctir1l1 Committee (FtC) regarding 0ilh~r or !h.:s(: 

optinl1s. but intend to ("{)fl~ult \yith the FEe aner you r~t,;ei"Vc {hI.: Coml111Hc('S opinion us 10 \\-·hat 

i:;; p(,lTnissibh: ~mdt'r House rui..:~> Each of the:;;,.' npliuns are disl..~ut;st.>d :3t:parnkly belov\'. 

Schmidt_0002 

11-6574_0274 
323

rh~ H,)nombk lean Scbmidt 

Page :; 

l:nder :.1 prcrYisiun of the gift rule, a ~vkmbt'T; ofltcer, or l'.mpl()y~e mily 

contribution or uther payrnclH to a legal ~xpen:sc fund cstab!b:hcd t~-ll' the benefit of [tbe 

that js oth(:rv..{s~ !awfuflv mad~ in 3.ccorounce with the restrictions and disdnsur~ requirements 

of the Cun111111ke on S1<~n(l8tds I)f Oftj;:ial ConducL'·.l l.'nder the Committe0's Legal Expense 

Fund regulations. a ~v1cmbcr not re(:d\,t~ Dr solicit donations w sud! a J"1md without pritH' 

approval of the Trust agr~~mcnt the Committee:1 

l)nder the Cornmittee's rcgulatiml<;, a fund may be (~stabli$hl'd only v'I'hcn th~ legal 

~xj)C·nse:;. aris\:! in conneclion with One of the !()!lov,.:ing matters: 

Th~ individual's c:.mdida-cy f()f or dection in federal (ln1ct:: 

The individual's official duties (.11" po')ition in Ccmgrc~s (incJlJdjl1~ a matter 

before the Standards Committee); 

:\ criminal prosecution; or 

i\ civil matter bearing nn the 1ndiviciu;J.l's r~pulatl;)n or tltllt:~S 1'or officc. 5 

fhl: Cornmhke \ .... ill not grant permission to establish a ftU1d when !t=:gal. expenses arise in 

connection \\"i111 a matter that is primJri!y p(,l'sonaJ in nature, such as a IHutrim,)!11al action,6 The 

ruk~s gO'l,:'erning, the operatlon ofa Legal Expense fund include: 

No contribution 111f(\' be :-;dicitcd f()/' or (lL"ccptc=d hy a fund prior tu the 

Committee's \\fitlen ~lppf(:.f\'al of the compkted trust document ,mel tlw 

tru.stee: ' 

A fund must bt cst;;~blish~d as H trust, adm~nist(:rcd by a trustee who is 

~~ntirelY 1Hd~DCndcllt u.f t11(3 \1emt1(>r and has no famlly, bllsinr.:,,;s or 

emplo),'ment J~t'lfltion.ship \yith dw Membec ') 

Tru~t tbnds can be used only to pay kgal 

inclirred in soliciting f()J: or administering (he 

5;~'-:: Sr(m,i.H~1s Conln~itt';-e Legal 

(\pp~i1dJ"( h) Jill: ~'t;US If"'IS:, Ef/;hs .tk'I/.'iJ.i Jt 3<).1 

Fllnd Rc.~~;d,rli(1!ls iUl 1. i I UUi~'" 1 !)9(J), !'~Tf i,J!"d 

IkgliLlilllfl0.;) 

Schmidt_0003 

11-6574_0275 
324

Tho Hc)1)cJrahlc kal1 Schmidt 

Page '* 

A fund may not :lGCq:H fth)rc than S5,OO() in a calendar y-t.:'itr fTOrll an} 

indjyjduai t.)r ~)fganizalion, but, in (JJxordance with lb..:: gift ruk, IlO 

cuntril:.'ution may he" {l('C'cpkd fro111 U tegisli:n:d lobbyi-:it 1.)1' [()reign agenl; Ii) 

Excess funds must be relurnt;;d \() lh.: ('ontrihuwrs~: i ami 

;-\ fund ma:v not pi.'Il' for k~gal s~rvi(:cs fcn anyone other than the named 

ht'neficiary cxc-~Pt vvith th..::: Committee's v/rlUen per1l1is~ion. \Vriuen 

Comrnittee permission is also required for any amendml.:nt of the trust 

document and any change in the trustee, 1.'. 

Om:1:: a i.ega! EXPL'IlSC Trust agrcc-mJ.:nt has been approved by the Committee, tht 

:V"kmber rnuo:.t file an ..::xecllkd ;,;op~' \\ith the Office of the Clerk, Lcglslati\'c Rc<;ourc~ C~nt('r 

\\ hich is placed on the publk record. U 'In uddition, :~\'rcmbers must rile quarterly reports 011 tjk 

IJublk: record regarding certain contributions and expendittlres lmd~r the Cnmnl1lkc's 

reguJation~.14 

The Committee has long advis~d f\·kmhcrs to (:onsuit with the Cornmittc~ prior to using 

t.:-ampaign funds for legal ~xpenses to ~llS11re that th(;: legai scryiecs are ones that the :".{~mbt:r may 

properly pay ,"ith <::ampaign funds. Hous-e" Rule 23, daus0 6 pro\'id~s as fbtJo\\'s: 

A .tvkmod, Dclegate, or Resident Comrnissionc.r .. ·· 

(H) shnH keep lh~ campaign funds of such individu:il ~epnnte 

fmm th0 pl.)r:-;Qnal fund::; o[such individual; 

(b) may Hot con ...... C'rt (:3mpn.lgn funds to -per~h)nal use in exc~ss of 

an amount representing rt::'imbursement !'pr kgitimaw and 

ycritiabk campaign e;.;peTlditures~ and 

(i.') eXc0pt as pl\)vlded in clause l{b) (If ruk 124], may not 

expend funds In.nn a c~"!mpajgn uc:counlt] of such individual 

that ar~ l1Dt attribtltnl"'lc to bonn lick (:ampaign or poLitical 

purposes. 

\Vhile the rule pe,.mit~ the LlSC of campaign funds for ><bum'! fide carnp3.i.gn or 

purposc:)," It docs not include n definition of thJt phrase. 'rhe Committet': has long 

LLf RegubHom" ? 

IYF R~.f:'Ulaji\)ils~: '; 

l.FF R~!.'\Jlijtion"c; I. 

1 FF Rc~: \l 1::1 ions ,. 1:: 

Schmidl_0004 

11-6574_0276 
325

The HOMWbk kan Scbmidt 

Pag~ ) 

I'vkmbvrs h.;'lv(' \",,'idc ,Jiscr~tion to determine "\vhethtr any particular ..:xpenJitun.' would ser\"c su,,::h 

pHrposc~, pn)\ idcd that the ;v1cmb~r does lH.ll convcrl campnign funds to personal \..)r offici.::)! USl~.s 

{(~ther than HS permitted by Ilou:-ie Ru10 24. chn.1St l(h»),I:' Put another way~ the ruk is not 

inttrprcted '''to limit th;: w:;e of <:ampaign funds stricqy to a i\·'1enlher's n.~decti0l1 campai~n." hU1 

instead is interpr!..:!ted "broadly to cncompa~s the tr:.!ditil)nal pl)liti-::ully-rcJatcd acth.itics of 

i\icmb('rs of Congrcss,,,lI, 

Tn accordanc0 \ ... ,ith these princlpil'Sj thi,..~ Committee hU3 determined that it L; generally 

permissible under House rutcs for Q \1emb~r to us.: campaign fund!) to pay for the ~kmb!.:'r':-; 

~)Wi~ legal f~ts ::h~ch ar~se j~n cormccth:m with the :V1ember'.s. campaign, election. or the 

p('rJormancc !.)f ohl~wl dut1~s. 

Th~ legal l'xpense~ you in.:urred in l~onn~clion with the Elc(tions Commissinn action 

were c1iJcl..'tly relawd to your candidacy nil' federal nlEc~ in 1008 .- 0111.) of the spedtie 

pennissihk types or Jctions under the Committc-e's L:gal Expense Fund regulations. Therefore, 

iT \\ould be generally permissible for you to eSlablish and :-:olicit n.wa legal expense tund to p:ly 

thest= fees already incurreJ. l\.toreover, the t'xpenses te· bl' incnrred in the Ohio Court casr;: 

lh~it app~u18 the E.rc.diGD C\)t11Jnissjon \; are also directly rdated to your \::andidacy j-hr 

fcdcntl (lrnC~ In ::O(nS. Therefore, it \vould be genera!!;: permissible for you to solicit for a kgal 

expense fund io pay these current and future It.'gullccs as \vell. 

There is no restriction under the C!.)n!mitt~c·s Legal Exp,,;nsc Fund Regulations thut 

\\ould bar the c::;tahlisi1mt':l1t of such a trust fund tu fKlY past kgul expenses, sn long as no 

solicitation or recdpt of Jonattt.>ns occullTd bcfofO: ~he (\)lnmiitcc's \\Titten approval of the trust 

agreement. Thus, before Y()l1 rnay begin 81.'ctpting or soliciting for donmions to cO\'l'f pa~t ~Uld 

future kgal expenses as c.kscdbed abo\,¢. the Committee must :ipprove your prclposcd trt1st 

agreement. U ynu arc inkreskd in pursuing (hjs option, p!e,t~c contact the C1Y1Unittec \\·ith a 

kttC'r approval 01 a specific kgal expense fund with .a drMt tru~t agreement and 

trustee pUrSU<1111 to tbe Committee's regul<ltions discussed abo\·e. 

;\~ ~lll alt~rnatlvi.\ \.\'C (~onclud(' l.Iut it b 'within your distretion to tlSl) 

legal ,,;xpel1st,.::-; alr~ady incurn . .'d in cnnn(;x:IJOn '..viJ.h tb~ Elections action 

th0-;G cxp~tis(:s a((: ror a kg,'ll adion ari2-ing l)tlt Df yenT candidacy for federal {)nk~, as 

;\"t;11 as your otllcial dutks und rcspllrisibllJtks. Sinc~ no money \\";;;n~ ~iw<mJcd in this 

caSt~. the ra:ymcnt (If kgal 1::--:peI1S¢S for this ,1ction do('''s not the prohibition on 

SI.<' Cumrn I'll ::-:ni'l,,;~\!-ds ~l!'O:"J1(.iai C·,mdu .. 't '\Ll-'l,')f) Opinion :\"0. 6. f <:I'i ii if r.."d ;u .. \l'r,mdi"\:u 

I-i~)!!,'..' Li;";:~ Hi/fwd:.1t 3-:5. )"hi 

Schmidt_0005 

11-6574_0277 
326

The r km.orah1c J~an Schmidt 

Pag(' 6 

converst,1n \)f .;[m1.}1;J.lgn r~mds to p~r~;l!l1al us .... ·. 11 is also \\ ithin your discn:ti0n to US"'~ tampaig.n 

l'tmds r~)r your kg~d expens~s in c0nncctlon \vith the pt'lKiing Ohio (\)tlrt C2lSC lhM the 

E1;:(tlon Conunisslol1'S ruling ITlati:::r be-cuu::;e thes(: expenses a.rc for:'1 legal actlt.)l) om (If 

the sam.::: facts rdating 1\) ~·\)Ur candidw:} and offi.cial dUlies at issue in thl..~ Elc\,,~tion Commission 

action, This authority ('xtends to expcnditure of funds from yO\lr principaJ commiucc 

for past expenses in connection \.1".'1111 the proceedings at the EkL!lOnS and (or 

(lH:rent futuro legal I.!xpcnses in conn~<;ti\"m with the Ohio Court c'a~c appealing the F:j ... 'ctic'll 

Cornnli%lon ntling., 

Finally, L1S d r0minder, you should he C;]utiO()llS t\) avoid any apPI,,':::l.ranc(" (~f specinl 

or ~HllitionaJ J.CCC.5S for TALDF or TCA b\.ised 011 your business relationship with these gn.mps. 

TCA did employ rr.:.:giskred lobbyists in the past and Y.:ry likely \I,-ill continue it) have issues 

pending h~forc Congress» Accordingly, \ve addsc you to keep in mind tJwse standards of 

condud during the lime ~\)U are wurking \\:ilh TALDF. 

Pur~uant t(l th,.:: Federal l-:ic('bm Campuign Act, tht;: FEe admini.'kr;') Gl scparatt.' set of 

restrictions on th.: us~ pf campaign funds, ;\.l!hough our undt:rstanding is that t!1\.: FEe generally 

permits the use of campa.ign funds and the ~stab!ishm~nt or t'xp~nse nmds for legal 

eXfK·.nses arising out of a :p.·1ember's cdngressinnal campaign and dWie:", interpretatiun of 

i"'EC Tcgulhtions is ontsi(le this Committee's jurisdict1011., If you have Hot a!n~ady don\;.' S(~, you 

should consult \vith lhe FEe to delermine 'xh('t11e1" either cours~ of conduct is p~rmissibk under 

tho applicable law and reglllali0l1,_ 

The rt'spon;;t above constitutes an advisor")' opinion concerning the application of 1 louse 

Rulc~ 23 Llnd 25 and the Code of Ethics for (Iovernmcnr S~!'vi(:c, The following Jimitatipns 

dPply to thi~ npininn: 

This advisory opinion i5 issued only to Repr~se.ntatjve Jtan Schmidt, the 

requ~sLOr of this opinion. Thh aJ\'i~or) opinion GHlllot he n.'lkd upon by 

any oth¢r indi\'idunl or entity. 

This is limiled to I.he prQyisions of the Hous,: ruks and 

the Code for Govt:mment S~rvice specifl((dly noted above. XO 

opinion 13 expresgcd fH' implj~~d herein reg::m . .Hng the app\icarion (',f any 

other kd~raL .state, or local }taLUl(', nlle, rcgulatil)l1, ordlnant:c. or OlhtT 

law that m,l~' be tn the proposed conduct (k;~cribcd in th1.":1 ictt..:'L 

l,h~ lntl.!nul Rev('nul.': ('ode aud lh<..' F~l..kral 

PI:: u'>lk 1)(' Llhl~S fl': (JI)\"I.'rnm ... nt :)·~'n ::.;:v ::t~m:~ :hJt.llJ g.ev'-'r!l;ll~'Ht 

\)[" :.p(.;ci~d r.:\'-I.!!·::' or p~i·,. :kW'~ 

jll ;l,.kii;i(;fl \\C ll'Y<: lh,;( 

"'i,e, -"'" J _,-iC,"C: ,'i' 

Schmidt_0006 

11-6574_0278 
327

[hI,': I \lJl1onlhk J0.:Hl Schmidt 

Pagt: 7 

This .:ldvi~iury npinion v,:iH not bind \)r ·pbligatc 

Committee on StanlLlrd:1 d' CHliL'ia! Conduct of 

of l~t:pp.:st'!H.ati\ ('S. 

o:ntity utht:r than tht: 

llnllcd Statl's- HOW~i2 

Thi~ is !imitl'd in scope to the specific 

descrihed in letter and does not apply to any o1her 

th<1t wlliLh :lppcars ~iml1ar in nature or S(ppe to that 

letter. 

i.:~m~luct 

including 

c.kscribcd in {hb 

The (\nnmittec will take no adl..,crse action aga1n~t you in regard to an:v conduct that you 

Uii<..knakc, or have undenaken, in good faith reliance lIpon thb advil.\()j'y opinion, ~() long (J~ you 

have pre~enl~d a nmlpktt' ~Uld accu.rat~ Slakmrnt of all rnateriaJ ra~ts relkd upGn herein) ,mu the 

prupo'Std Ctlnduc(. in practice (:onfol'lTIs with the informatiul1 you provided. as '-h.1.Jn:;~SI..\.1 in this 

opinit.m, 

Changes 0f othef den:~h.)prnents in the law llncludir.g. but not Ilmhe:d to, the CoJ~ ,_u' 

Off'ici,t\ ConducL Hous\? C()lnmitt~(.; gllidanc~, advisory statult:S, '·"''''''-'''"m· 

;":~1<.;.a: 1m\') may affed the or t:nndu .... iuns dl'uwn in thi" 

r~S~f\ cs th~ right to recunsidt-r thl;.· l~ue;-;ti,-)n~ und jSSll~S rah,ed in advisor).: ('pinkm. ,mel ttl 

rescind, !lH.,dify, or terminate this npinilll1 ifrequired by th~ interests \..'lfthe Hous('. Hu\vever, the 

Con"lmitkc wilt rescind an advJ.sory opinion ~-m!~ jf r~;:k\·ant and makriat L'lds \"\'cr..:' not 

completely Hnd accurately discloied to the COlT'lmil1ee (It the time the opiniun was issued. In the 

('\'tnt that this advisory opinion is rnoditkd or t~rminatcd~ lhe CommiHee will nul take .any 

:lcb;(.'"l'sc :J.ction 8.gainst you with re':1pt'cl to any action -taken in go;:.)d ·hitl.1 rdi~mcc upon this 

advisory opinll'n ~o long as such conduct or ~uch ~H .. ,tion was prompt1~ discontinul..'d upon 

nOll 11L'atiun nl"th-: modific~njon or tc'rmination of this advisory opinion. 

fC lOll k:!\,t dny funher questions. pkase contact the Committee"s Office of ,\dylct' <111<..1 

Educ<1tion at c:;.knslon 5-710.1. 

loe Lufgren 

Cbir 

ILJB:pgp 

:-)inccrdy. 

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EXHIBIT 24 

441

tr:ln"~lt'~-""; (}rn-~,:'n(;y, 

,'(~:-.h ~h;j 1;:,1\';: nd \" 

In ::'ly ",Ul{lid::~,! j~w L'"h.'l li c;.n : ..',; ::OlJ;'( 

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Schmidt_0013 

11-6574_0389 

443

EXHIBIT 25 

445

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J <'" fh<.' 

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h" H\l!l:-'~: !,hd," Hi nnd <,'> ::':""s;i;. th'.' { ,wmr,;p-",;:<.."';'" :;ppr< ". (1 I tn (,JH.I.'! il);() ,I k,' 

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c:--:-:p ... n.;;;,; {Itlst f:, lx'in.~~ <::'>t~~bji~;lh.·:;:. 'H:<,' PUtT":'::': nf;.h-..' prupos,::d jTL:'!' i~ t" p!'(,yidl..' ,I 

pl\~r('r n H;;!l;,~ Ii! ;\I..'L~:p\ tnm~; ,I,J:, (1:' n :nn,,'~·. <HJd S,.'f\ th<.' 

tLe iq:al lklJ h<:X'i'l,.i!ld 

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Schmidl_0016 

11-6574_0391 
446

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Schmidt_0017 

11-6574_0392 
447

EXHIBIT 26 

449

from: 

Sent: 

To: 

S!Jbjoct: 

,}(;e~ 

M<Jy ',/</u pl~:;:':I~;;D qet i.3 Gl..ipy of the proPQ~.H.xi (;ont.i::qnncy fee (.lfFeHrneni.? 

Thanks 

H(,aihDi" 

Hcnth0.t" ,jon(.'s 

Cnunsei 

COnlrp:HCf) on Stand;jrds of Offi~)a! Conduct 

U.S House ()f Rept"6snnt.';-ltiVt")S 

DC 2Ufj'1j 

225·/,!{J3 

Schmidt_0018 

11-6574_0394 

451

EXHIBIT 27 

453

The 'j\lrki::dt Am!.::eienn Jl'j:::d DflfpHH; Fuud (r/\lJ)Vi tIl n·pr{,,;.;pnt 

Conp.'{)~;;';WOl\lall ~J(:an SdU'Ilidj· t() ii1.ignl(> ~~ d(d~J!HHlion H{!,<-!im'l. 'l),n;ld 

hl'ikorlnn in Ohio I":>taUl <:{l\U·!.f:~. TtH' OYUi't eOi~(~; nftiv~ Utipli.lou willlH: :!:--;~Hnwrt h.v 

),\,18. Sehmhll, 'f'hi' pnrtii·;<.; HR1'('~"~ to divide' ~)I}v;){l dHn);~~~'H~.; l'h~ov('.r<.'d I.hl'OUi~h 

fin,!l judgnwnt. ~;dtlf'uwut., OJ' otl\f..'l'wi~(' ;.;ub:";j';·ln1 h!'~~IHl.'.;i? of dw dl'i:'nn~·)j-inn 

li1Jgl.dl(Hl, but only ,Jft.f·'l' eOr'L" ~Hlvn h •. '·pt fin<{ ypcuvefl:d he\' 1\:1:-.;, Sch,mhil Tj\L[)I'~ 

<".vil.l nol, ol.hnfW"i}'Q bp j;"jtnpi.·n~·;}JiNi j,y Ilu' {\~nf,:l'C~<H\Von.ti.l.)), 

lhuen Fein 

t\t.tornc,Y, Tnrki~h AHWt'icau Lng.nl Oefnn;:'::(1 .Fund 

David s"n'!..",an 

ALlnnley, Tnrkinh {\rtH,r;ean Lpg".! J.)('ii)1\ii(' 'Fund 

Schmidt_0019 

11-6574_0396 

455

EXHIBIT 28 

EPRESENTATIVES Form A .MAY f 3 2009 

AL DISCLOSURE STATEMENT Fm "'" by Member.;, office ... , and employe.. 

-! ',,' J T[--:-

-\. ::'G\-lM \ Ii- Daytime Telephone: 20;<. 2;;<S AHII:56 

r." , ._ - :",;, 

v.s. 

Stale A $200 penatry shall be assessed =-I against anyone who files more than 

Termination 30 clays late. 

 - ANSWER EACH OF THESE QUESTIONS 

e (e.g .. saLaries 0"- VL Oid you, your spouse, or a cJependent child receive any 

vesO 

,I 

eporting period? NoD reportable gift in the reportng period (Le., aggregating more 

es than $335 and not otherwise exempt)? 

/I yes, comofet. aod a\tach Sched.f. VI. 

nation to charity in VII. Did you, your spouse, or a dependent child receiVe any 

vesl8l 

r article in the D repDftable trave! or reimbursements for travel in the reporting 

es NoD 

eceive 

NoD 

VIII. Did yoo nold any reportable posruons on or before the datsNoD 

d or hold any Yes of filing in the current calendar year? 

end of the period? If yes, complete and attach Schedule VIII. 

purchase. sell, 

NoD 

IX. you have any reportable agreement or anangement with 

vesO No0 

on exceeding an outside entity? 

It yes, complete and attach Schedule IX. 

ave any reportable vesD NO[] Each question in this part must be answered and the 

 period? appropriate schedule attached for each "Yes" response. 

-- - --- - --

PENDENT, OR TRUST INFORMATION - ANSWER EACH OF THESE QUESTIONS 

usts· approved by the Committee on standards of Official Conduct and certain other need not 0 IV1 

ort details of such a trust benefiting you, your spouse, or dependent child? Yes No CJ 

port any oftJ8r assets, "unearned" income, transactions. Of /labilities of a spouse or dependent child because 

 answer '"yes" unless you have first coosulted with the Committee on Standards of Official Conduct Yes 0 No 

co en 

M 

..... '" '-I' 
I Name 

NCOME 

f earned income from any source (()ther than the filer's current emp40yment by the u.s. Government) totalling $200 or 

 year. For a spouse, list the source and amount of any honoraria; list only the source for other spouse earned income 

ow. 

nal Guard or Reserve pay). federal retirement programs, and benefits received under the Social Security Act. 

Source Type Amount 

•• __ ______ .... _nn_m 

.... -.-..... . 

_______ 

Pension 1 $9,000 

.. _-

........... ....... 

I s.vco:"E $ALAlV{ rvAo 

.. _--

10 charity in lieU of honoraria, use Schedule II. 

en en 

M 

..... '" <I' 
D "UNEARNED" INCOME I·ame S<-'r\K,,:>' I·age.k..ot q] 

BLOCK B BLOCK C BLOCK 0 BLOCK E 

Value of Asset Type of Income Amount of Income Transaction 

Indicate varue of asset at close of Check all columns that apply. For For retirement plans or accounts that do Indicate if the 

reporting year. If you .use a valuation r:s to: asset had 

method other than fair market value, hweslments, you may write "NA.g For For all other assets, including allIRAs, purchases (P), please specify the method used. all other assets including all IRAs, indicate the category of income by sales (S) or 

indlcale the type of income try check· checking the appropriate box below. . 

If an asset was sold during the reporting in.9 the box Dividends and 9Ven, tf rein-- eXcI"\imges (E) 

year and is included only because it exceedirYJ 

generated income, the value should be Check "None" if asset did not gener- or generated. $1000 in 

- . I _ .11'1-1-1 ,1·1 _- If only a I 

A! B C f) E F G H i I J K L· I _._ I II III fV V VI VII VIII IX X XI portion of an 

I . I g .. 

§ asset Is sold. 

.f 11 ' 

15 I ! 

-- II) 

1 

0 E 

8 § 8 

0 g g -q 8" § a 

<:> 0 :5 0_ q g oj tn 15 

I 8_ q 8 g -&9- q 

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o 

:i g go 8 ;; 0 

oooc 8· o 

I I I ......... c & 

I .... .... .... 0 0 0 0 

please indicate 

as fonO\\lS: 

(S) ipru'ial) 

See belON for 

example 

p. 

S, 

I q i f I .... :5 gOd !if I 

I 8. g g q q g? d) :.;: z 

z,;;; .... *1;' f); ::l ;;, *. <3 " 0 ll' ;-1 'I "I 1 'I 'I ·1 J 

-- .. -D ___ ----- ---- -- c ___ --- ---- ---,V-l----J----------------- I il-j:><4t-LLJ _tJ.SJeartJa.9... 

! 

§ & g 8.- S 8 

.-.. ;_ .. ... -.. -......... _ .. 'x' +···I···_-.. r' .. ·-··l 

 

:;: , x 

IX 

xii i v 

)( c.. 

k 

Ix -f--- 

III !xl III t tlltrtlt tt I i' H1Uli 

. .s 

 unearned income. use next page. 

o 

o 

'<I" 

.... 

It) 

If 

.... .... 
460

~_1---+--+--+-+--+--+--+--+-+--+-l-l_f-1---+-+--+_+--+--I-!25.000.001 - $50.000,000 A 

Over $50,000,000 rNONE 

DlVIOEND:> 

RENT 

None 

X. $1-$20D 

$201 - $1 ,000 

$1,001 - $2,500 < 

$2,501 - $5,000 

$5,001 - $15,000 . . $. 

1-1---+--+---1-- .~,_ ... ~ ._""_ l-l-l-+--+--+-t- _ _ _"-l-_.l-_4--_-I-.:c.'~ •. O~O.:..:' -=-'."".O"".OOO"'-c-__ ---'S_<~ $50,0(11 ~ $100,000 

$100,001-$1,000,000 x 

$1.000.001 - $5.000.000· x 

l> 

3 

o 

c; 

*5 '" OJ 

9..Q 

:;0 

.., 

o 

~ 
461

$25.000,001 - $50,000,0(:0 "" 

OVer $5:0,000.000 r 

NONE 

")It DIVIDENDS 

RENT 

~~~~~~~~~~~~~~F~~~~~~~ ___ ~~~-+-+-+~IN~TE~R=ffi~T___________ a m 

~~+-+-~~-+~ __ ~+-+-~~-+-+~ __ ~+-+-~~~=C~AP~I"~~~G~AI~N~S ______ ~ [;f g ~~+-+-~-+-+-4 __ ~+-+-~-+-+-+-4 __ ~+-+-~-+-+~EX~C~E~~~D='B~L=IN=D~T~RU~ST~~ ~ m ~ 

Other Type ot Income 

(Specify) 

None 

~+--+-+-~~-+~ __ ~+--I----_ .... -I---L~----+~'-~+--I-~ _ .. J--:$1:..:5~,aa::.cI::..-",$5",O,~OOO~ ____ --,";;..J l I $50,001 - $100,000 :S 

$100,001 -$1,000,000 x 

m 

,. 

3 

o 

C 

::J m 

as 

;;0 

8 

3 

m 
462

Jeannette H. Schmidt 

United States House of Representatives 

Financial Disclosure Statement for Calendar Year 2008 

Listing of real estate assets held by various family partnerships and jointly with siblings. Jean Schmidt 

owns 25% of all of the partnerships listed below. 

(I) OT Realty Enterprises LLC 

Percentage owned: 25% 

Comer of Loveland Miamiville Rd & Branch Hill ! Guinea Pike, Loveland, OH 45140 

Land leased to Walgreen Pharmacy 

Value of percentage owned - $250,000 - $500,000 

Net Income for percentage owned for 2008 - $15,000 - $50,000 (rent) 

(2) OT Realty Enterprises LLC II 

Percentage owned: 25% 

Comer of Loveland Miamiville Rd & Branch Hill I Guinea Pike, Loveland, OH 45140 

Land leased to Kroger 

Value of percentage ov.ned - S250,000 - $500,000 

Net Income for percentage owned for 2008 - $15,000 - $50,000 (rent) 

(3) OT Realty Enterprises LLC III 

Percentage ov.ned: 25% 

Comer of Loveland Miamiville Rd & Branch Hill / Guinea Pike, Loveland, OH 45140 

Land to be developed in the future 

Value of percentage ov.ned - S50,000 - $100,000 

Net Income for percentage owned for 2008 - zero 

(4) Jennifer Black Et All 

Percentage owned: 25% 

Comer of Loveland Miamiville Rd & Branch Hill I Guinea Pike, Loveland, OH 45140 

Land adjacent to OT Realty Enterprises LLC II 

Value of percentage owned - $50,000 - $100,000 

Net Income for percentage owned for 2008 - $1,000 - $2,500 (rent) 

(5) Gus Hoffman Second Family Limited Partnership 

Percentage owned: 25% 

Corner of Loveland .'VIiamiville Rd & Branch Hill! Guinca Pike. Loveland, OH 45140 

Farm Land 

Value of percentage owned - $500,000 - $1,000,000 

Net Income lor percentage owned for 2008 - $2,500 - $5,000 (farm crops) 
463

(6) RTJJ LLC 

Percentage owned: 25% 

Corner of Loveland Miamiville Rd & Branch Hill! Guinea Pike, Loveland, OH 45140 

Farm Land 

Value of percentage owned - $1,000,000 - $5,000,000 

Net Income for percentage owned for 2008 - $2,500 - $5,000 (farm crops) 

(7) RTJJ LLC 

Percentage oy,'Tled: 25% 

Moore Rd. & Bantam Rd., Clermont County OH 

Vacant property 

Value of percentage owned - $50,000 - $100,000 

Net income for percentage owned for 2008 - zero 

(8) RTJJ LLC 

Percentage owned: 25% 

1232 SR 28, Milford, OH 45150 

Commercial Rental Property 

Value of percentage owned - $50,000 - $100,000 

Net Income for percentage owned for 2008 - $2,500 - $5,000 (rent) 

(9) RTJJ LLC 

Percentage owned: 25% 

1236 SR 28, Milford, OH 45150 (SR 28 & Floyd Place) 

Residential Rental Properly (3 small homes & vacant lots) 

Value of percentage owned - $100,000 - $250,000 

t\et Income for percentage owned for 2008 - $2,500 - $5,000 

(lO)RTJJ LLC 

Percentage owned: 25% 

SR 132 & Judd Rd. 

Vacant Land 

Value of percentage owned: $15,000 - $50.000 

Net Income for percentage owned for 2008 - zero 
TIO 

nge by you, your spouse, or Type 

g year of any real property, of Transaction 

or other securities when the 

I 

$1,000. InclUde transactions 

 description ot any exchange w w I '" 

n between you, your spouse. z 

ase Of sale of your persona! 

:I: 

Q 

a: 

nly a portion of an asset is :> [L '" w 

l sale"). See example below. 

sset 

mmon Stock (partial sale) X 

y: 

-

S'<>C"" X 

1)c?bt-r '"f 

, ;;. 

4 v 'v s,-;-Ot.: __ . y: -

.. 

7" 

. 'j. .. ! 

v r-. I 'J.. 

. _-

x:.... I 

 - o,o:-:.L TO \ 

-

....... --_.) 

....... 

I' 

• - 't 

[:: .z::; . .'::':''Y.\,-v y. 

",>, '1 

opied if more space Is required. 

I Name 

Date Amount of Transaction 

_.-

(MOIDAY/YR) B C .D E F G H I J K 

or 

Quarterly, a ..!-8 g.g § Monthly, or .0 §§ §g 5& Bi-weekly. It .0 gg g 00 00 §§ applicable 00 °.0 8. 0 00 ,'" 

-

... 

10-12-08 X 

"h5'0'8' ')I. 

"1-\5-015' )I 

(.,-3-0& ? I--

.. 

/., 308 F 

25 .Yi? X 

.5 08 

Il'\9-a\<? yo 

It .\'l."g y:. 1--. 

. 

--,--

2-\2.- 1)1-

z.-I'Z-Ol? I-

. 

2-- \<--os Y. 

L,- \<1-0 8 .. iL- -- '----- '----- - '--

on 

o 

..... 

on 

<I' 
_ .. _ ....... 

ange by you, your spouse, or Type 

g year of any real property, of Transaction 

or other securities when the 

 $1,000. Include transactions 

f description of any exchange w w 

on between you, your spouse, :'.' "', z I 

hase or sale of your personal " () "J .,. 0: 0 

only a portIon of an asset Is " " 1;\ "- 

al sale"). See example below_ "' 

sset 

mmon Stock (partial sale) X 

tPl 

'Ywo"...,.. y. 

>,,) 

.. 

-

y.3f\",/'=> Y. , 

----1_ 

. """ ----- r 

Q'l'\t,..Jl'v\ I\(' T='>, )0 1 

\'ik)?:I_ 7-

'f' 

''f- ... _ .. -

Y- ._ .. _ .. _._ ... 

l:iZ 'i'" 

._ .. 

tA'V>:> i-

... 

i' ! 

copied jf more space is required. 

I Name '>c"""'0"\ -

Date Amount of Transaction I 

----,---

(MOIDAYIYA) B C D E F G H I J K 

Or 

Quarterly, ,,-§ §§ & ,g Monthly. 13_& or .0 If ;;15 §§ ,0 .co _0 00 <ig 8 §§ &0_ applicable U l:! .. 0 .. 

-

10-1Z-08 X I 

L-12,'O,;? X 

10 -3, -06 )I. 

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o -z,vog i: 

, '-1-1')-0;;<; 1-

w:zs-08 f 

\0:'\ -oS '-- -- '--- '--

<D 

o 

..... '" '-I' 
CTIONS 

ange by you, your spouse, or Type 

g year of any real property. of Transaction 

or other securities when the 

 $1,000. Include transactions 

f description of any exchange w w 

on between you, your spouse, '" " z « 

hase or sale of your personal <> "l J: a: 

only a portion of an asset is => « 0- '" W 

al sale"). See example below. 

sset 

mmon Stock (par1ial sale) X 

''''''i) )I 

CO ,'I,· ...-I.,J ...... '.:;:. f 

f" 

X 

\'.. _ .. _. 

'Y..,...,\:) )< 

\ i'VIl- i='vw;) 1" 

),.) .. _- _.-

'fl 

-

.. 

. _- l' 

'f 

'f-

1-

> 

1 

copied if more space Is required. 

I Name \f.:e? ·C>E<>.,v :,(. .... ..., ,.,-.-

Date Amount of Transaction 

(MOIDAYIYR) B C ! 0 E F G H I J K 

or 

Quarterly, .!-8 0 

Monthly, or ·8 ""8 C;8 §g §§ 80 <: 8i-weekly. if .!-g 8.g &0. §-g g go. applicable gg fifg U "0. cig gq lifo 

.. .. ;;Sj. 

10-12-08 X 

1-1">-06 /-

'2--,7,-0'11 )( 

-08 i- ! 

'"::1. 1}t0 

t'-'\. 'f( l\ 

\"'\ )< v"",' \a..' f\ 

! 

H. Y- :r;;. bxl\ 

11 f -;"., 1\ 

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-

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11 y. 'til"<: ;z,.'( 1\ 

c • 

...... 

- 1-. 

"-

o 

"-

'" '-I' 
r=-RU D \ 

YMENTS AND REIMBURSEMENTS 

ary, dates, and nature of expenses prO\lided for travel and travel-related expenses totalling more Ihan $335 received by 

d during the reporting period, Indicate whether a family member accompanied the Iraveler al Ihe sponso(s expense, and 

t at the sponsor's expense. Disclosure is required regardless of whether the expenses were paid directly by the sponsor 

y the sponsor. 

vided by federal, state, and local governmenls, or by a foreign government required to be separately reported under the 

.S.C. § 7342); travel that is required to be reported under the Federal Election Campaign Act; travel provided to a 

y independent of his or her relationship to you. 

City of Departure-Destination- ILOdglng• 

City 01 Rot"rn (YIN 

Date(.) 

N 

Y 

_L.,.:c..,.. ...... "r.\ 

- I 

Food? I 

(YIN Member £ncluded? 

(YIN) 

Number 01 days nQ! 

at sponsor's expense 

N I N I Nons 

y T Y 2 Days 

v 

\ \>"$ 

'r' I 

'f lv' (\.10 i'vE 

.",.1- ----/-------/ 

-.. -I--.---t-----------1f-----1f------I--

----+--------1 

-I---- -----I 

y be copied it more space is required. 

00 

:1 

.... 

Il'l 

... ... 
 

I Narne \Lv ::\r""" '>C \-1 M, VI I .89.1- of 1] 

 uncompensated, held during the current calendar year as an officer, director, trustee of an organization, partner, 

r consultant of any corporation, firm, partnership, or other business enterprise, any nOn prom organization, any labOr 

er institution other than the United States. 

 I; positions held in any religious. social, fraternal, or political entities (such as polftical parties and campaign organi

norary nature. _ : 

Name of Organiwlon i 

" .. ,< ') 1 LLC I 

1'"'<;'" \ \ \ 11 I I J 

Le, too< 

TS 

 terms of any agreement or arrangement with respect to: future employment; a leave of absence during the period of 

erral 01 payments by a former or current employer other than the U.S. Government; or continLIlng participation in an 

ned by a farmer employer. 

Parties To Terms of Agreement 

--_ .. __ ._ ... _._ .. 

. .. _-

. 

_ 

.. 

__ 

... _._ .. 

-

_ ._ .. •• 000000000_0000 __ 

 if more space is required. GPO 200S 47-141 

'" 

:' r--

Il"l 

... ... 
469

EXHIBIT 29 

SENTATIVES 

page 1 of Ji. 

FormA . = ',::L,',T!' -

CLOSURE STATEMENT For use 0'1 Members, officers, BrIef employees 

,'n 22 r" 

[I,'T: 

57 

..... 

_ '" .... 

"'t1 M \bJ [jaytime Telephone: 22S /JUt: JS' <I' 

(Office USR Ont)') 

A $200 penalty shall oe assessea 

t agBinst anyone who files more 

! Terminalion Date- 

Termination than 30 days 

NSWER EACH OF THESE QUESTIONS 

salaries or vesj8 NoD VI. Did you, your spouse, or a dependent child rec-eive any 

period? vesD reportable in the reponing period (Le .. aggregating more than $.'335 and not otherwise exempt)? 

com("lete and attach Schedule VI. 

o charity 

vesD No0 

VII. Did you, your spouse, or a dependent child receive any 

NOD 

n Iht=:! reportable travel or reimbursements for tra\fB1 in the reporting 

1::: 

meamed" NoD VIII. Old you hold any reportable positions on or before the date Yes vesr2] NOD of filing In the current calendar year1 It yes, complete and attach Schedule "til. 

._ .. 

•• .. L_ 

e, sell, vesl1:] NoD IX. Did you have any reportable agreemen' or arrangement vesD 

eding with an outside entity? 

n- yes, complete and attach Schedule IX. 

reportable 0 NOfei Each question In this part must be answered and the 

 Yes appropriate schedule attached for each "Yes" response. 

ENT, OR TRUST INFORMATION - ANSWER EACH OF THESE QUESTIONS 

PTOVM by Jhe CommJitee on Standaros "r Official Conduct and certain other "elo!ooptoo' need not v: 0 rYI 

s of such B: trust you, your sfXM1se, or dependent child? ,es No LLJ 

 other assels. ·uneamed" income, transactions. or 'iabirtties of a spouse Of dependent cllild oocaLlse 0---==11 

 "yes" unleSS you have first consulted with the Cornmihee on Standards of Ofticial Conduct. Yes No 
[ NO: \Z'iO? ,IE>-,'" :::"d-IH,;;r; IpOQeJ.-oI].v J 

E 

income from any source (other than the filer's CiJ-rrentemployment by the U.S. Government) 10talltng $200 or 

r a spouse, list the SOurce and amount of any honoraria; jist only the source for other spouse earned income 

m or Reserve pay), federal retirement programs, and benefits received under the Social Security Act. 

Source Type Amount 

-----------------f-;A=pp=m=_=-,;" .. =C:;:h"'rng FA9 t $8,000 

.. : .... : ..-.. _:··-..___. ____ . ___ . ____ .. ----.- - -.. 

Spouse NA 

< t'I??o ">_ Sf" '-'So£' .s", MIA 

--+-------------l - ----

-----+--- -----1 

y in lieu 01 honoraria, use Schedule II. 

('oj 

..... '" '-I' 
EARNED" INCOME I .::s;e.I*- . St_ r-\0 -'- I" 3> 

SLOCK B 

Value of Asset 

lli 

: ,£; 

I toi 

=> 

II: 

IQ "' 

" Q "'ill 

<L Q « x Q ill 

)(- ·:--j·1 

.. -. x· _0°_-

. I 

I 

ed incomf'l, use next page. 

tfmilya 

Ixl x i XII porliOfl otan 

asset is sold, 

please indicate 

as tolICWS: 

§ § 

g g g §. 

011Il L en ... ..- (B- J -

a I:...... -- ..- 8 8- lil 81 7 i g & 

(I) ,_ .... ' g g 8 . - 8- 0 :0 .£/ .. ;i U :2 Z; 12 ;;; ;;; 6 

---[rrr' ---- ----- j( :>( 

(51 (partial) 

See below for 

eXi:lrnp'e 

P, 

S, 

__ 

M 

; 

..... 

It) 

If 

... ... 
EARNED" INCOME 

SLOCKB 

Year-End 

Value of Asset 

 C o IE IF IGfH II JJ.IK IL 

§ ! QQ.g",gg 

2 g g & g g 0 

i 'f ;. 5 ".8 l 0 0 & g goo 0 0 w 

& ci g g g 

SC,",'""'0' 

BLOCKC 

Type 

of Income T, 

I z .5 '>; 

21 t- II 

fu t- - Z - ..::: w a. C,.) g § (3 

SLOCK D 

Amount of Income 

I In 1111 qv VIIV'/IVIIJI/XI x I XI 

g "I I 

-;& 

i I 0 , g 8 i g :; § ol§§§_;}g.:i 81 iiI'l -I'''; ill .. I ::- ;; I I ;; 

iii' \ I I I _ .... ;; 0. 

BLOCK E 

ITransaction 

p. 

S, 

E 

i 111;111111 1:111 : 11111 t8 j 

 I IY- 1-+ 

more $pace is required. 

'<I' 

.... 

'<I' 

.... 

It) .... 
475

~ -; I : 1v =< ?l "' ()({) 

I I -" o (') ~:l: ~ 

1 II ' , 1 1-\ 1/ I , 

~I~ i~ g Ii ~ ":>:3 ". J rT1 til I ( 

*' !,\ t':S1 t ~ 1/1 

~g I~ li~ "2: 1/1 '? Glc, iI' 16 .<: ~I~ 'ol !!I- 0 r- ~ ! '1' ,V' V- G> " (\ I~ f p ,r-

~ I~ ~ J £ 1,' .. J rT1 (/'1 J ~ I~ r ~ Irl :> g?= ~ vi", :;\I~ ~ I

r :111 r, , je $ i' ~ lb 1 -<J £ £' ~ 1

9 ~ !~ 1:(/ ~J i lb 

I~ ~ I~ " ~ 0

, t ~ 5" .::::> 5' ~Ii i ~I ~ ~ f n =-CI) 

~' ~ I~ 0 9- ~ I~ I~ r 2 3 J CI) 

I? <- ( bl "!\' ? ~ CD ~ ~ f r~ le- I ~ U :f G"~ ~ ~ \~ ~ r r VI 2-CI) 0 

~ ~I ~ , I ~ ,.l, ,I c: s> 1\ CI 2 z - CD 0 

, ~ None » c:: I $1- $1,000 '" Z 't<- '"J... ~'>< ,,)( $1,001 - $15,000 0 IT! 

')t. ,l\. '1-'" : $15,001- $5O,ooa 0 > )( "f., ;; ::tI 

f( f>( >< $50,001 - $100,000 m tE~cc Z 

IT! ~', I;:" , Sloo.OcnI- S2IiO,ooGi' " CD .. .--

$250,001 - $500,000 0 ".m", 

2.~R ~ 

s5oo,ooi'- $i ,000 ociIX' '" .. :> '" Z lo. C') 

$1,000,001 - $5,000,000 - 0 

ii' 

$5,000,001..'_ '$iS.OOO,Qilti!: .. !!: 

$25,000,001 - $50,000,000 '" m 

, Ova; $50,000,(01) ... i<,f,Z "- NONE 

-,.:; -,<. ')(. y. -.<. fi(,' l>Z -1.. '1-..,. ~f,C OIV10ENOS' 

RENT 

I-i. INTE~Esr S!. '" CAPITAL GAINS 3'~ 5 EXCEPTEOIBLINO TRUST n'tJ 0 

o CD '" .----

I I 

3 0 

<D i Other Type of Income i 

I I I ISpecify) 

i r '/-. -;.. -f-, Nons - ~,.: );.)< I ';< 1'1. )t. $'-.5200 = ~ -'(1)( F>' ..,. .... $201 - $1,000 = ". ~ 3 

Y 81,001- $2.500 < 0 f c: $2,50~ - 35,000 < :> '" -5 55,001 - $15,000 < o 0 -" $1500, -$50,000 ;§ 5"0 

) ) ;§ 

~ n $SO,OO~ - $100,000 0 

I 3 $100,001 - $1,000,000 >< CD 

$1,000,001 - $5.000,000 X 

I I Over $5,000,000 X -:;;-

"0 --11'\i .:v rv '\! h, _JI --vI .4/'-'<J-V ~I~ ~ ~ 

.. '" . 

I ! ill I iii 

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:> 
476

Jeannette H. Schmidt 

771 Wards Corner Rd. 

Loveland, OH 45 HD 

United States HOllse of Representatives 

Financial Disclosure Statement lor Calendar Year 2009 

Listing or real estate assds held by various family pannerships and jointly with siblings. Jean Schmidt 

owns 25% of all of the pannerships listed below. 

(I) OT Realty Enterprises LLC 

Percentage owned: 25% 

Corner of Loveland Miamiville Rd & Branch Hill! Guinea Pike, Luveland, OH 45140 

Land leased to Walgreen Pharmacy 

Value of percentage owned - $250,000 - $500,000 

Net Income for percentage owned for 2009 - $15,000 - $50,000 (rent) 

(2) OT Realty Enterprises LLC !I 

Percentage owned: 25% 

Curner of Love1and Miamiville Rd & Branch Hill / Guinea Pike, Loveland, OH 45140 

Land leased to Kroger 

Value of percentage owned - $250,000 - $500,000 

Net Income for percentage owned for 2009 - $15,000 - $50,000 (rent) 

(3) OT Realty Enterprises LLC III 

Percentage owned: 25% 

Corner of Loveland Miamiville Rd & Branch Hill! Guinea Pike, Loveland, OH 45140 

Land to be developed in the future 

Value of percentage owned - $50,000 - $100,000 

Net Income for percentage owned for 2009 - zero 

(4) Jennifer Black Et All 

Percentage owned: 25 % 

Corner of Loveland Miamiville Rd & Branch Hill! Guinea Pike, Loveland, 01 145140 

Land adjacent to OT Realty Enterprises LLC II 

Value of percentage owned - $50,000 - $100,000 

,,"et Income for percentage owned for 2009 - $ \,000 - $2,500 (rent) 

(5) Gus Huffman Secunu I"amii)" Limited Partnership 

Perct'ntage 0\\0 ned: 25{)/o 

CornerofL()vdand t\liamivilie Rd & Brunch Ilill' (iuinca Pike, L(lIdand. 011-151-10 

Farm Land 

Value of percentage ,mneu - 551.10,1.100 - '\ I ,000,000 

'd ~nC(\rYH~ for p~rc.~ntag~ r"\\n~ll f('f 100Q - ,,\2.~OO - "\-;.000 (fQrm ('wp.:;;\ 
477

16) RUT LLC 

Percentage owned: 25% 

Comer of Loveland Miamiville Rd & Branch Hill! Guinea Pike, Loveland, OH 45 [-10 

Farm Land 

Value ofpercenta~e owned - $[,000,000 - $5,000.000 

l\et Income for percentage owned for 2009 - $2,500 - $5,000 [farm crops) 

(7) RTJJ LLC 

Percentage owned: 25% 

Moore Rd. & Bantam Rd., Clermont County 01/ 

Vacant property 

Value of percentage owned - $50,000 - $[00,000 

Net income for percentage owned for 2009 - zero 

(8) RTJJ LLC 

Percentage owned: 25% 

1232 SR 28, Milford, OH 45150 

Commercial Rental Property 

Value of percentage owned - $50,000 - SIOO,OOO 

Net Income for percentage owned for 2009 - $2,500 - $5,000 (rent) 

(9) RTJJ LLC 

Percentage owned: 25% 

1236 SR 28, Milford, OH 45150 (SR 28 & Floyd Place) 

Residential Rental Property (3 small homes & vacant lots) 

Value of percentage owned - $100,000 - $250,000 

Net Income for percentage owned for 2009 - $2,500 - $5,000 

(IO)RTJJ LLC 

Percentage owned: 25% 

SR 132 & Judd Rd. 

Vacant Land 

Value of percentage owned: $15,000 - $50,000 

:--let Income for percentage owned for 2009 - zero 
ONS 

ns by you, your spouse, 

n)i security or real prop

ncJv.de transact.ions that 

 of any exchange trans

Ol,lSI;! or dependent 

dence, unless it gener

s sold. please $1) indi

a gain in excess 

nis income on Schedule 

n Stock (partial sale) 

II j 1 HIE 

I I 

____ ----=- _+-'I'--t- I I I I I I 

, 

- b - J i I 

"i- _ M 'f lrl_- _J 

_ i- \"I "t L -, \ I 

'f- "" ...;. L i 

'f. i .. 

oj. 

-.--+-

+--

ed if more space is required. 
ONS 

s by you, your spouse, Type 

y security or real prop

clude transactions that 

ot exchange trans

ouse or dependent chiL

dence, unless it gener

s sold, please SO indj,.. 

of Transaction 

a in excess 

his income on Schedule 

LU 

<n 

« 

:I: 

" 0: " "-

. .. m--=t 

n Stock (partial sale) 

LU 

'" z « 

I 

:I: 

'-' )( 

LU q 

_0 

go "a.Z:; 

"'" 

I W :3'"<,>,,, M \J>'I I P.g. _::t """ U of T","_oo 

B, C 0 ElF G II I I J K 

or 

Quarterly 0 0 T""" 8 ..:.. 0 g 

Monthly, or '8 _0 _0 -8 88 go C> 

-

...... pj bl " go " 00 '0 0ci 8m' 00 00 '0 ci0 "' 0'" 00 00 .... 8 0 ap Ica e ...:'!i g 1G g ::; g IR-IR- oIA WIA (f)1A (/)b';Io lAtA 10'710'7 tAb'lo Ot.".! 

t-- - - f---1 

10-12--09 I I x 

l'f I t:t-b'-J(;f+::''t'--cj,jJ.-I----j-+--+--f--_+_-I 

-,,,,,ow I 1- I HI '1 -5Du"!'l)'! I I I I I . i I 

7l...PrrJ 

O[ 

. -L-----+---I--I; 1 1---+--+1 }j 

, g -<)'1101 .1 "-----.. .1 -t---j+-- 1.'5 d1 LJ 'I H I I 

V, V 

; I I 

<-,s. \)( I I I, 

I y. 

<:,-,--, _I--'-'Q."--__ --ll-_-! 

LI-'k7 .rP/ , 

;1..-;1->, 0') I: 

ed if more space is required. 

en 

..... '" <I' 
ONS I Na"", ::)\::1>",-> X¥tMcm 

ns by you, your spouse, 

ny S€oCurity or real prop

clude transacUons thaI 

 of any exChange trans

Otlse or dependent chil

dence, unless it gener

$ soLd, please $0 Inl1i

a capital gall1 in eXDeSS 

ttis income on Schedule 

Type 

of Transaction 

UJ 

OJ 

'2 

u 

a: 

:J 

"- ff; 

UJ 

'" z '2 

UJ 

jj8 

oil 

ueJ 

Date Amount of Transaction 

F G H I I 

I (MO/oAYIYR)1 BI c or K 

o '!'o! Ii 

00(1'} EHOO "",,"_\ fr,)<oR 

80 ':'81 g 0 

gg 8 

qo. 

Quarterly, 

Monthly, or , 

Bi-weekly, if I.:. :s 10 :s 

applicabfe g 

""'''''' r.:f.I{It 

I 

n StocX f.partial Sale) r" -1- ,-+---+-

-rl') _ __ _ L---i-

'" 0,"1.-0'1 I i I 

III : · r <" ,Jl l j I I I I 

"", 't--n:' '\<. _ . )I. - -t-I r-I .. 

'" 1\ -1:2 -/Y1 ... I I 

'/.. II-i)-ott )<. I T - - -

.:; __ -I T 

> '{ [l , .. , 

NC. w....,<;:> " 

::J 

____ _____ 

1 1 1 Iv TV'11 1 , 

.."" 0,,,,,,,,- )<- n--15t>l'1 

,, FVl-J" l' 10-/9-u /' 

S. )"- .. 

('vI"';;' 'fJ _____ r2S- _.I _ 

Fv",,, 't> , 7-v,;Cf i. I r 

w,... f" /0 iQ-Oj -;: 

ied If more space is required. 

o 

'"<I" ..... 

It) 

If 

.-.-
ONS 

ns by you, your spouse, 

ny secUrity or real prop-

nclude Iransactions that 

 of any exchange trans

ouse or dependent chil

dence, unless i1 gener

§ sold, please so indi

a capital gain in excess 

hiS income on Schedule 

Type 

of Transaction 

ill 

'" <t 

:r: 

(.l 

II: 

:::> 

Q. 

"j 

;')j 

ill '" 

\I 

w 

_ 0 .0 

!i 

• ID 

a c 

(0. 

M 

'-'<!J 

I Name 'kr. 

Date 

(MOIDAYIYR) 

or 

Quarterly. 

MontIJly, or 

Bi-weekJy. it 

applicable 

B I C 

.:..8 Ci8 

00 00 

tF.I-tI) 

Amount of Transaction 

o 

.0 

"' .. 

ElF, G H 

§g 

;;iti 

00'00 

&: : 

0 

C:::o 166 0 

ggl88 .... g .no g;-c:i 

x 

(partial sale) 1'0--12:-09 +---+-4--1 -

CRV\7 

rv"'\€>;<. 

v"""E'.{Z 1-1'R""'" I I I 

5-IS-D1 

(.-l,·df 

'I- j-+---

;<.. 

L-/- II-M 

'i-;ll-D/f 

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 I 

Y'clN t:> 

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s·;l.<-> v't 

[_2<.- d1 

\?Q l-l!:> 

.'F",,-,\") )<. 

(, ,7 -0'1' J. 

£;., JJI::> I .,.. I )' I ,- W v l I I'" I i-+-...l..-.1. 

<,,. I ' 

17-)0 Jt )i. 

-fHf 

)< 

J 7- 15-0,,{ )'-

I- ,)<. 1 , ., 1 r-C, 

(.,- I,-cf/' )<. 

h-'Nb 

rU\Jt:. 

331-ocy 1)( 

If Is- )-D? j,< 

ed If more space is required. 

N 

..... '" '-I' 
ONS 

ns 0'1 yau, 'fOur spouse, 

ny security or real prop

clude transacbons that 

 of any eXChange trans

ouse or dependent chil

dence, unless it gener

s sold, please so inc:li

Type 

of Transaction 

w 

CIl 

.. 

I 

" a: w -' 

w 

'" Z .. 

J: 

.. 

au '" . 

I N,'me \Z.;j' \..5->+':-\ \\Yr 

Date Amount of Transaction 

o I E I F I 

, ,0 1"':'-0 0 

(MOIDAYIYR) B c K 

ci0 00 00 00 

1 1 I - 

+-- +--+ -+ - 1- -

x rlQ-12-09 

a capital gain in e)(cess 

nls Income on SchedLJje 

.l.' \1 w "'" 

or 

Quarterly, 

Monthty, or 

Bi-weekly, if 

applicable "'-81 58 \58\88 0_ 0 cici 

Eo"II tfJ. f;fl "h tfJ.\F.I 00 V) 

§§ gg Ull< 

(g __ -+--

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1",.,,"'0 If

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1-

I j-

._.- .. _-

)l 

-f! 

1 'I I 

M:> 1-

'f. 

Co-li-[!f/ 1>£ 

7- 17-d1 L-J! -+-_ -l-+---T1-:=- -- -

1-'-- I 

___ _ i-. I 'f I I r- I 

ed 11 mOle space Is required. 

[ 

t----f -t-+--

I 

i +---1 -

j 

i 

i 

N N 

'<f" 

..... '" If 

.... .... 
TIONS I Name \ -"" Ipage lSofl.0_1 M 

by you, your SpoUSt'L Type . 

any security or >eal prop- of Transaction Date Amount of Transaction 

Include transaClJo. f1S that - 0 ---[- ----f'-r--1 - "[ 

(MQ/DAYfYR) BCD E FIG I H J K 

sidence, unless It gener- w \..LI (,) -g or : 

 is so'd. pjease so (!) ¥ Quanetly I 0 I ,.:.. 0 ' 

1: g Monthly. Or .. a ...:. 0 ...:. 8 g §; g 

n a capital gain in excess § 13 It :.- § 88 8 g 81- 8 g 

 this Income on Schedule 0.. if) UJ g g 

U WtR- th'-'l- WtFi IJllFJRw.tAf.A 

+-+-+-_1----_ 

llon Stock (partial sale) 1v-,2-DS 

1 

pNr) , 

£7C: -i 

I", 

__ £'11::_ !: 

E-TI" )< 

S,\" r 

' .'/- -;, 

D -J-""--

":'_ y -" :n· C9. L -Ef' 

+ 'F /0 G, -cPr y: _ __ 

 'f It. -" -<=-'1 t. _ 

= i' G, - \ -or f- -L 1-

c- 

- 'f. 1& - IS Sr '-i- . _ --l 1_ ±± 

-- lJ.l-\-9:I_4.1<_t--- --- --t - -

 _____ 1--_ )l I- IrIS-{f) 

+--

pied if more space is required. 

'"<I" ..... 

It) 

If 

.... .... 
TIONS lliom. '>L'tr', ,YT 

ons by you, your spouse, f Type 

any secu.nt)l or re._ - I. Date Amount of Transaction 

JncJll{j1;' lrarl:).;7Cilons Inat .. ,_ __ _ 

on 01 any exchange T :gj ! I 'I H ai B - C 0 E F G K 

-g Quarterly, 

g Monthly, or \ ,0"" a :.. 0 

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TS AND REIMBURSEMENTS 

s, and nature of expenses provided tor travel and travel-related expenses totalling more than $335 received by 

he reporting period. Indicate whether a family member accompanied the traveler at the sponsor's expense, and 

ponsor's expense. Disclosure is required regardless of whether ttle expenses were paid directly by the sponsor 

nsor 

federal, state, and local governments, or by a foreign government required to be separately reported under the 

342); polttical travel that is required to be reported under the Federal Election Campaign Act; travel provided to ' 

pendent of his or her relationship to you, 

Date(s) CIty Of Departure-DestlnaUon- Food? _ B.raml Y Number of days lli!1 

City of _rn (yIN) (YIN) Member Included? at sponsor's expense 

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I N:. 31'"_':-',,-, C;, q"-; \ ".. I peget(oof lk.1 

ensated, held during the current calendar year as an officer, rnrector, trusteD of an organization, partner, 

tant of any wrporation, firm, partnership. or other business enterprise, any non pmfit organization, any labor 

tion other than the United States. 

ons held in any religious, social, fraternal, or politir:al entities (such as political parties and campaign organi

ature. 

Name of Organization I I 

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f any agreement or arrangement with raspect to: future employment; a leave of absence during the period 01 

payments by a former or current employer other than the U.S. Government; continuing participation in an 

a former employer; or publication Of a book. 

esTa Terms of Agreement 

-_._-- -------

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space Is requited. I.WO·2:l;tl{l 

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487

EXHIBIT 30 

489

?(1!:LOf'GRHI,(.f,LiRJflt'iA 

CI·;'\II~ 

DAJ~I"-LJ rp'{LO:~~ 

COlN~:L TO';'H~(;H""'JA 

i'I RLAKI: CIIIf,AI'.-l, 

CIII~~ COUNSEL AND STAFF fll~F."T~"jR 

The H01l01'able ChaIles It Rangel 

U,S. H:'>w.itl ofRepre~rl,utiY~5 

COMrvllTfEE ON ST,\NDNmS OF 

OfFICIAL CONDUCT 

Octobe" 29. 2010 

2354 Raybum Hocel" OfFce Bn;[ciing 

Washingron, DC 20515 

Dear Colleague: 

Thi::: responds to your te~ter of October 2), 201 0> rcque~(jtl,\s 

and accepting pro bono or reduced-fcc legal representation in C01111C'..ction 

PW('{':t.;oing5 currently pendi.:og r.tg.ainst you- bd'ore the CumJnltfec, 

Ju [;U:·'''J~F'.Ii.L'''i1AM,l. 

:~-!\M,'!~G l'~rU,"lIC;~,t, MFMBEFt 

SLiTE HT_<,T·iE (",\i>ITO .. 

[2C:1i nf,.., 'n" 

In Y{Jur leller, you stale, "1 am C1.sking the COn1mitlee W s.ppro\'~ my r-lcddng , , . counsel lon 

apro bon.o or reduced fee has!';] without me or the counsel helng ilccused of seeklng~ receiving ()1" 

providing gift l'cpresenta,tlou. 'l You also state, "rn the aftcmativ(~, the COTIunittee ern arrange for the 

HDU.t:t: to pH)' for my COUll'::;el. ~~ Vv'::; have construed YOllr request as (l reql10st for an acl',.'isory opinion 

from the Committee's Office ,Jf' Adviec and Education.!' 

VlhiIe I·rouse Knies authorize the Cotnrnittec: to conslder reqll~sls for advisory opinio.1"Js, 

such authority is limited to '·th~ g-enc;al propriety of any current or proposed conduct" of {he 

inquiring individual, 2 1vloreover, in providing v.rdtten rc..'lponscs tD r{;ql!Cst~~ for an ()pinion) the 

Conunittee has a long~established poHcy of addressing "the conduct only of thv inqLJ!Ting 

indi\'i~ua\ or of persons fpl' wbmn the 11lLl,uiring inuivHlual i~ responsible as rtl!~] empl{\ying 

authoflty."· 

Because yOUI' letter dues not provide specific details abom hmv 01' t1:om "Nhom YOH \vould 

seek legal representation) we c~mnot defh:..Hively address ... ;o.,'he111t.'T the ~1L.tivities d~scribed. in )'o\lr 

Idler are pennh:sible under applicable House rdcs, iaws, rc:.gLlleri()ns or of her applicsi:'lJe 

~~1.~tml:.m.l:~ oC conduct. \V..::, (;.aH~ hmVeVl::T, oiTof ym.i. some general guidance 011 the rules and 

standards of conduct applicable w trlembers of the House that ure r.ek:v.:mt to j\"lur inquiry, 

1. FACTUAL llACKGROlNlJ 

A:;cordlng to yOUI' letter and publkly-av~tilabJc.ll"::lteriah·l, the hf~t::.kgr{)und on this matter is a~ 

f~)llows. The Committee has be0n conducting formal ~li8ciplL.'1my proceedings Intt) allegmlt)fls tilai 

1 See H('IlI~C Rllk 1 i, d, J(f~)O); Committee Rule 3(h). 

", House Rule ll., d, :~(a)(4). 

Committee Rule 3(d). 
490

'n,e Houomole Cbartes B. Rangel 

Page 2 

you violated House mles, la~vsl reguhitioTls, ur oth:;,..'f applicabJe: standards of conduct. On July 22) 

201Q, an. investigative 8ubco1'Tl1uitke tnmsmittOO s Statement of AHeged Violation lSAV) to the full 

Comm1tt\X. You ate ,,:.ulfc.ntly sch.,;oduled to appear before 811 adjuctkatory 3uhcommitt2:f.' on 

Novem"ber 1 :.\ 10 i 0, fer an adjudicatory hearing on the allegations -charged in the SA V, 

Dnf'ing tl1e COUY:<C of the proce~d.ings) you were rep1"t'semed by the \Vw::hington, D.C., Is\v 

finn of Zuckerman Spaeder. To date, this repJ"c8cntatioll has gm"!.crat(xl kgal bills of over 

$2 rnillicm. To date, you have largely ll~ed ft.lll,(.1::;; lro111 )\RU' principal campaign conunittee to pay 

those expenses. However, m~ of October 14, 203 0, ZUCkC!111oXl Spnedcl' v{ithdrew nom :::l(~tvj.r.lg i:i.S 

your CtlUllseL As of the ddte of your leiter, you hav(~ hxm. uD.nble to S[1cure nt:v,/ GOlITlSe] to represent 

yml in this mHtil'1'. 

YOUi' OdobeJ' 25,2010, iettr;r inquires about th(~ petlnissibiHty of two options. for securing 

Hnd accepting legal <lssls1ance: (1) haV1Jig the Tlouse fen" your counsel; Dr (2) ,:tllowmg you (u 

i:lotic·it prjvd~ counsel to represent you on a prv bono or n."du('ed-tcc basis, The l'cUlfljnder of 

this lett.er provfdes gene-ral guiuance on each cfthesL.! options in h.lrB, 

II, LEGAL AC'Tl:lORlTY AND ANALYSIS 

<\. Cnunsel Paid by the House 

Your first proposal 1':; thatihe CorrJ.nlrtct.:: or the H01]s(~ of Rcpros('·.I.ltativ0S 6oS~, wtole "pay for 

any iUlthcr legal cosl.s incurred in connection vAth the adjudic,anon of tbis matter. A p1'Ovisinn h) 

the Committee's mles provide2- a resPQndent in discipli.naty pl'oc.xdings beDxe the Com.mittee with 

the right to be represented by cmlflseL4 Hovveve,r .. the rule also expl'e.ssly pro·vides. "that any such 

lepr..;sentation is Hto bo provided at the respond:::nfs ovo .. n ,~.'i Thus, Lhe Committee, in 

promulgating its ruJc:s, has weighed and l'cje-cted the option 1he govcuunenL paying for legal 

representation tor individuals v>lhom the Comnlittee is Investigating. 

A federal stattlte also l'o2;strids the "Use of J-iol.lsc- funds to the purposes for which those f~lhds 

\Vere appropriated.6 Pursuant to this .st:rt'...1te, ~U1y funds offhe IJOllse may b0 u::1ed enly to periorm, 

or pa.y for, the offIcial governmental duties ofth~~ 1vh:;nlh(>.1', C;OF'l11l1ttee, or 0tber office to whom the 

funds ",,(ere appmpdmed. Bee-ause yOW" lcga.l representation for pw-poses of the disciplim!TY 

pro:xe. .. dings before th..:; Cm11rnIltcc is a matter \vhoUy rehted 10 your 0\vn official duties, no funJs of 

(he ITow.:;e 0the,r (baH funds apprepdated to your congressIonal (Anc(~ tor tb.I':' conchtcl of nftidal 

congre.,>sional husiness (i,e,) lYfembe.r\{ Representational Al1C·'v(U1(,C" or fy1Rl\) c.ould be 

expended [vI: tha( purp0se lhe statute. Hovilcver, Wt' note tbat tho Committee on House 

Administration, raUlcr GnTl this Committe~, ho>....o;; juri~didlon over the approval of [f.~imburscD1cnts 

from your l'vm.A. i 

'I COITunittee Ru.le 26(<1). 

'!.i 

6 11 U.S.C §1101{a), 

7 We lJJ1de:rst'.::nd that the C01111nitwe on HDnse: 

l'epr{':s~.nlElliou (If ,1 M,~nlber in tl C'Jrfqnitkt: 

funds l;tlCd_IJ're silch ~:'mem;ef. are 110t 10 (Ie 

Admin., Member"s f{w;dhuok, at j ("OrdimwJ-" (),d n8C8.?SWY e-"YHl.I(S{U 
491

The Honorable Charles 13, Rangel 

Page 3 

In sum, it appears that Committee n;;tes, House regulatiolls~ an.d a federal statute would 

prohibit t.\e House fi:om pl'crvlding you with 1~g1'l1 representation £.)1' th.:: rcma~ning phtises of the 

disciplim:.ry proceedings. before the Committee,S 

B. Soliciting or Accepting ~-'rec or RedueedA"F'ce L-t'gal Semc{;ls 

The t~econd option addressed in y,m1' letter invohlt;S you 3t~eking private eOllTI3(:} to represent 

you on a noycost 01' reduced fee basts, This propos.:.l1 i11lpli,:::.ates <t.thics provisions govemll)g bolh 

fu:.ccptancc of gifts and sollcitancn c f ill in gs of vat1.lfj, 

I-louse 11l1es define the term "girt" to mean: 

a gratuity, favor, discount, entertainment, hospita1i1y, lean 

forbearance, or adler ikm having moneta.ry value. The term 

includes gifts of services, trai.ning, trilnspoj'ta.tioll~ l<)dglllg, and 

meals> whether provided in kind, by purchase or a ticket, payment 

b. t1dVmlCe~ or reimbtlr1:>t~ment after the expense hu-, been incllr-red,t) 

The definition of gift expresc-;ly includes giftcl of services. the ·,,:aluc or 

provided to a Me.l1:1bel' at no cost would be dec]jJ('"d to be B. gift the gift .mh:. 

JImy net acc.ept any gin, except as BpedficaHy pcnnitte.d by House rules,u 

sefvkc:-l 

Ivlembers 

One of the pennissible exceptions to t.he prohihitiml on gifts is for contrihutions legnl 

expel1s\.~ fund by ~omconc other t.han. ~"L Itjgist<.:TCd lobbyist or agent. of a foreign prln'.::lpal. 'r his 

exception provides that a Member~ oll1ce-f; or ~mployee lnay ~iCcep~ '\.:, cOlltnb-:.1tiOl1 01' other 

pa:;n.ncnt to a !-egal expense fund estabtished. for the heneHt. of a \1ember, .,' o1'11cel" 01' 

empluyee of du':: House that is otben-vise lavlfully made in aCLtm.lam.:c "vHh t~e restrictions Qml 

disclosure requitcmcnl.;; of the Corrn.nlLtee on Standards .of Offidal Conduct. ~1~3 The Committee 

I"fa.;: expressly stated that SUdl a fund is permis~ihle for legaJ expenses that arise in connection 

with a maHer concer.ning iTt]he in4ividuars duties (11' pos!tiOll in. Congress (including v. 111fttier 

before the Standards COl!lInitte;j)."t(, If Y()1.i. did establish a valid legal expense trust in relationlo 

this would be perrnitled to solicit donations to the truSl of money or in-kind service~ 

or discounted legs.l ~~ervice8), provided ;:wch solicitations and donalions were 

-----,----,-----------------------

Member's official and represer.tf~tior',al duties to the di:itrict lrolYl wMicl'! d-ecled are reilnhufsahie , ") (emphasis 

added), 

~ H0l1se Role ',;5, c1. 5('~)(2)(A). 

:~ As a ger:.eral matter, 

iodividual's official st:xtl..ls would be 

11 How;e Rui~ 25, d, 5(rXl )(/,}(i); .<:ee al,\'c HOllse Ruio '23, ('1. 4, 

12 See House R:J.ic 25, cL 5(i;)(3)(E). 

1'; Jd. 

H 2UO& House Erhic!; Manuaf at 64 
492

The Honorable Charles B. Rangel 

Page 4 

made in compliance with Committee regulations reg<.wciing j~gal expense. trusts. 15 The rules for 

!.'::RirtbHshing, maintainil18) and providing public disclosure about sueh a fund are I,.:olltuLned in the 

appendices to the 2008 House Ethics Manual. lfi 

Tn addition} because an importaJlt aspect of a 'Member's respDllsibili.tj is reprc:s(;!iting the 

interests of hi::; constituents in irl::1Hcrs ill wlrich (he federal QOVel1lElent has an interest the 

Comrnittee has determlned that pro bonD assi8tancc 11) partkipat~ in cer ...aill actions l.nvo1'1til1g the 

federal gOV0111n10nt falls within the gHt J11le exxpHon for contributions to Jegal expense fimd..;;,17 

Specifically, as stated in the 2008 House Ethics ,'yianuai, a ivlcmbcr may accept pro bonD legal 

assi~taTl\.~e) without lln:~it~ for the tbllowing purpose3: 

• To file an ili"Tlicu~ brief jn his (,)1' her L;i:l.paclty f:3 it mmnbcr of 

Congress; 

!I' To participate in a civil action challenging the validity of any 

rtxlerallaw or regulation: or 

To parliclprrte in a civil action challenging tbe lawfulness of an 

action of a federal agency, or.an action "of u Jhlcra! oHlcll.ll taken 

in an oftkial vapRclty, provided thai the flGtion concel'll:'-] ,1 rnutter 

ofpubli.c b:!tcl'est, rather H1till'(1 nmtkr U1.fX[" is personal in :t:Jltnrc" i8 

The C~omlTIitiee has permitted the aocepiance ()f pro bono legal services fbI' tllC P1UTO,'::C:S listed 

above hL~Ci.mse such ;:::ervj0es would b! .. ~ to e:lli:1ble II fvlember to [i.llfill his official duties as an 

advocale- fm 1he greater good of hIS consdtllents due tn the subject mat'"[.\.~r of tho;:, litigation.19 Thlit 

prInciple of servlng the greater good would not ~ met tbJough pro·<;"iding legal St3l'vic.cs to defend an 

individual Member againsl alkgations uf mi.sconduct bv an individuallvtember in a dTsciplimHY 

action by the Committee.20 ~ 

J~ SCll Comm. on Stand.:trds ofOffkir:l Conduc" ~;LegaJ Expense Ft:mil H.eg'll{1,Lkm~" 11 (JUIlt: JOj 1996). 

reprirtted m 20M House Ethics i1Ia.nu{l.l at 3:)4, 

1(, See g<!neraJiy fd, fopr~'''l!Jd ifi 2f)(J{? Hotls(; Ethu.:~· Manual m pagc..'i 391+-96. 

n See 2008 Hou,\'c Ethft;;i!; Afam,ai ~tt ti5. 

t8 ld. 

reJ)re$~nt<:ttjon, we C811110t. i1S noted 

pototttial1y appJy in fr:is mil-Her. See HoJUSC Ruic 

approvi;rl an Ilnwlic.jted reduceJ 

the approved armngeme.nt inv,;::lved 

We also note 11mt the C'Affll11'ti1lee 
493

f)1\~ Honorable· Ch.arles 13. Rangel 

Page 5 

In any ease, a feder....u statute prohibit~ 1.1embers and House stafifrom soliciting aJ.1)'thing of 

Valtl{~?l This statute givGS this Cornmittee~ a:::: the sQpe.nrising ethics office for the· Housel the 

authority to issue ntles 0::' regulation,:, providing fbr reasonable exceptions to this: prohibition.22 

Under this authorHy. the Commitlee ha<:; pe-~l"rjtted Memh: .. '1"g to solicit for a legal expense fund that 

has been established a.."'1d npproved by the Committee in ac.;:ordance with the Leg~d Expense hmd 

Ref:,'Ulatlons,23 The Com .mittee has never approved th{~ solicitation of pro bOJ7D legal services 

incurred in eomlcction with a discipHnmy matte!' beforc the Committee, unless t~e solicitaul..)n V;"&-S 

h)r the donation 01' goods or senices to ~'i vi.:1lid It'.gdl expense ll'ust estCtblished for that purpose, 

Based 011 the forcgl)i.ng authority and pJ.'ecedent) because the subject maHer af thl..: 

COirlnlltiec lTIVesligation conc~rns your (x)Dductj mther than the actions ofihe federal government, it 

WQutd not be permissible for you to :wlicit OJ: accept pro bono or reduced~fe€ kgal representalion in 

ccnnei::tion \vith the ongoing disciplinary proceedil1t2 ..,s~ absent the eslablit:;L.'Il(jnl uf ~t legal expense 

fllnd fer snell PU!'pos(', 

Hl. CONCU;SW" 

AecorciinglY1 as explained more fully I-louse /;llid Committee nues and the 

applicable ±ed;::ral statutes would prohihit tile Hrm~e paying f~rr Y011r legal representation. 

In addition, it is likely that. absent the est8blishment of a valid legal ('~p0nse fund for that 

purpp:;;e, you may not solicit or accept pro bono or JedllCed~fee repfCs~nhitioll relatt:d TO the, 

dlsdplinnry proc.eedings before the Committee. \VhiIe not proposed as an oplion in yOU1' letter, it 

would be permissible fm you to em.ablish J. k~ga! expense fund to accept c.ontributions of: 

money that could be used to defray any legal expenses incurred in comlt'ctlOll \:y .. ith the 

Committee disciplinary proceedings; or (2) jn~.kind donations o[ free 01' d::Si:.onnlcd t:ervices 

for tb~ samt': purpose. As stated above, any SllCh Jegal ('xpense fund "\'vould to be 

l~stabHshed and maiDtaincd in accordance with tile Committees L~~gal Exp·~nge Fund 

Regulations. 

IV. LIMLTATIONS 

The response above CCl~lStitUtcs an advisory opinion conccming lhe appl1c<:ltiol1 of House 

Rule 1 L clnusi;~ 3~ Hout\c Rule 23, clause 4; House Rule 25) c.lausc 5; CommiH~c F .. ule 3; 

CummlLtee Rule 26; (he Legal Expense Fund 5 U.s.C. § 735';; and 31 U.S.C. 

§ 1301. The following Ijmita[ion~ i;lpply to this 

" This advisory opInion is lS8ued ,)nly to Representative Charles H. Rangel. the 

requestor of this opinion, 'lbis iicivisory opinion cannot be relied upon by any other 

h1dividLlal or entity. 

21 See ill. § 7353(b)(11. 

Fund P .. cgulations, reprinted in ?O()8 fiouse Lthhs Man~~af at 394 w 9Q, see al.w 2()08 
494

The BCmtitabie Charles B. Rang(~1 

Page 6 

~ This advisory opinion is limited to the provisions of HODse rule,:;: and regulations and 

[t.~derat ~tBjutc specifically noted above, No opinion is expre3s\..\d Dr implied herein 

regarding the application of ftny other federal} state, OT loc.al statute) rule. regulati{ln, 

ordinance, or other Irt'iN that may be ~lpplicabb to the proposed conduct dC8cribed in 

this leUer. 

It This advisory opinion ~vm not bind. or ob!ig[JlC .:Hty entity other than the COTIiJJllliee 

on Standards of 0 ffidal Conduct I] f die U nlted States House or Representatives. 

,. T111& advisory opinion is limited in t=ic·ope to the specific proposed c·m:duot described 

in this letter and. does not apply to 2:.ny oihrr conduct, induding that whLen apP(..':aTs 

similar in nature or snJpe to that described in ihis letter, 

The COITrrnittcc will take no ndvel'se action against yO~1 ill regard to 311Y conduct that you 

undertake, 01' have unuertfll<en, in good faith rdianee upon this advisory opinion, so long as you 

have presented a complete ::'J1d ac.curatc statement of all olHierial facts relled npoll he.reln, ar:d the 

proposed clmducl in pratt~ce D(mll:nrJ..s with the intormattun yon provjded~ ?IS addl'cssed in this 

opitJion, 

Changes or other in the law (induding, bUl Hot limited to~ the Code Df 

Official Condu0t, House rules, gddanc.e, advbory (lpinions, S13.tutcs, reguiations or 

case law) may affect lhe or conclusions dnnvll in this advisory opinion. The Committee 

reserves the right to the questions and i:;;sues l'::lised ill this udvisol'Y opinion and to 

!'esc,iud, modify, Ot tc.cminalc l1J1s opinion ifrequrreu hy the interests: nf1he.llouse. HO~IA.,7evcl', the 

Commilke will re~mind an e-dvisnry opinion only if relevant and material t:':1.cts "VGfC not 

completely and accuratdy disclosed to the Cotnmittee at the tunc: the opinion was issued. In lhe 

event lhat this advisory opinion is modHled or 1errnJn3.te.d~ the C'ollluittee will not tukc 

adverse action against you with respect to a..'1y action taken in gL)od t3.lth reliance upon 

mlvisory opt!,jOll so 10ng as such conduct or tmeh action was promptly disc·ontinued upon 

notiflc-ation of the modifical1on or termination of this adv~sory opinion. 

Tf )'I)U have any f,mhcr questions! including fhrlht!' infonnation on establishi.ng a 1egal 

d<:.~fen-3e fund, please contact the Comroittc(:'s Office of Ad.vice and Education at extension 5-7103. 

ZO{~ Lofk,'Ten 

Chair 

ZLiJB:ccd 

Since-rcly~ 

1-p~,~ .In BOHner 

Ranking Repub1ieml J./leu.l.ber